Opinion
17937-21L
02-28-2023
TIMOTHY J. BUEHLER & EMI MORISAWA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On February 18, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Emi Morisawa, on the ground that no notice of determination pursuant to section 6320 and/or 6330 of the Internal Revenue Code had been sent to petitioner Emi Morisawa with respect to the taxable years 2012 and 2013, nor had respondent made any other determination with respect to Emi Morisawa's tax years 2012 and 2013 that would confer jurisdiction on this Court, as of the date the petition 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 Emi Morisawa is granted. This case is dismissed for lack of jurisdiction as to Emi Morisawa, and references in the petition to Emi Morisawa are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Timothy J. Buehler, Petitioner v. Commissioner of Internal Revenue, Respondent".