Opinion
28486-21S
10-18-2022
EUNICE A. BROWN & CLIFFORD A. OLSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Peter J. Panuthos Special Trial Judge
By notice dated July 7, 2022, this case is calendared for trial on the Court's November 7, 2022, San Francisco, California trial calendar. On October 14, 2022,respondent filed a motion to dismiss for lack of jurisdiction as to petitioner Clifford A. Olson and to change caption. Respondent asserts that no notice of deficiency or notice of determination was issued to petitioner Clifford A. Olson for the 2018 tax year. In the motion respondent also states that petitioner Eunice A. Brown died on or about December 16, 2021, and that Sherry L. Olson is successor-in-interest and the proper documentation is attached to the motion as Exhibits A and B.
Premises considered, it is hereby
ORDERED that respondent's aforementioned motion, filed October 14, 2022, is granted in that the Court does not have jurisdiction as to petitioner Clifford A. Olson for the taxable year 2018. It is further
ORDERED that the caption of this case is changed to read: Eunice A. Brown, Deceased, Sherry L. Olson, Successor-In-Interest, Petitioner v. Commissioner of Internal Revenue, Respondent.