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Brownstein v. Comm'r of Internal Revenue

United States Tax Court
Nov 2, 2022
No. 16830-22 (U.S.T.C. Nov. 2, 2022)

Opinion

16830-22

11-02-2022

WAYNE BROWNSTEIN & DEEDRA BROWNSTEIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge

On August 24, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Deedra Brownstein and To Change Caption, on the ground that no statutory notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioner Deedra Brownstein with respect to taxable year 2019, nor had respondent made any other determination with respect to Deedra Brownstein's tax year 2019 that would confer jurisdiction on this Court, as of the date the petition herein was filed. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so. Accordingly, it is

ORDERED that respondent's Motion To Dismiss For Lack of Jurisdiction as to Deedra Brownstein and To Change Caption is granted. This case is dismissed for lack of jurisdiction as to Deedra Brownstein, and references in the petition to Deedra Brownstein are deemed stricken. It is further

ORDERED that the caption of this case is amended to read "Wayne Brownstein, Petitioner v. Commissioner of Internal Revenue, Respondent".


Summaries of

Brownstein v. Comm'r of Internal Revenue

United States Tax Court
Nov 2, 2022
No. 16830-22 (U.S.T.C. Nov. 2, 2022)
Case details for

Brownstein v. Comm'r of Internal Revenue

Case Details

Full title:WAYNE BROWNSTEIN & DEEDRA BROWNSTEIN, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Nov 2, 2022

Citations

No. 16830-22 (U.S.T.C. Nov. 2, 2022)