Opinion
28551-21L
03-08-2023
PATRICIA C. CARLSON & HENRY F. CARLSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 25, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction and as to Henry F. Carlson, 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 Henry F. Carlson with respect to the taxable years 2013 and 2014, nor had respondent made any other determination with respect to Henry F. Carlson's tax years 2013 and 2014 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 Henry F. Carlson is granted. This case is dismissed for lack of jurisdiction as to Henry F. Carlson, and references in the petition to Henry F. Carlson are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Patricia C. Carlson, Petitioner v. Commissioner of Internal Revenue, Respondent".