Opinion
4364-23
08-25-2023
MIKE W. CHANCELLOR & BETTY CHANCELLOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On June 15, 2023, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Betty Chancellor, 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 Betty Chancellor with respect to taxable years 2017, 2018, 2019, and 2020, nor had respondent made any other determination with respect to Betty Chancellor's such tax years that would confer jurisdiction on this Court, as of the date the petition herein was filed.
On the same June 15, 2023, date, respondent also filed a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Year 2020 and To Strike, on the ground that no notice of deficiency, as authorized by section 6212 and required by section 6213(a), I.R.C., to form the basis for a petition to this Court, had been sent to petitioners with respect to taxable year 2020, nor had respondent made any other determination with respect to petitioners' tax year 2020 that would confer jurisdiction on the Court, as of the date the petition herein was filed.
Although the Court directed petitioners to file an objection, if any, to respondent's motions to dismiss, petitioners have failed to do so. Accordingly, it is
ORDERED that respondent's Motion To Dismiss For Lack of Jurisdiction as to Betty Chancellor is granted. This case is dismissed for lack of jurisdiction as to Betty Chancellor, and references in the petition to Betty Chancellor are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Mike W Chancellor, Petitioner v. Commissioner of Internal Revenue, Respondent". It is further
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction as to the Taxable Year 2020 and To Strike is granted, and this case is dismissed for lack of jurisdiction as to taxable year 2020. References to that year in the petition are deemed stricken.