Opinion
8192-23S
07-12-2023
PHILLIP CLEARY & TARA SATTERFIELD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 28, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Petitioner Tara Satterfield for Taxable Year 2020 on the ground that no notice of deficiency was issued to petitioner Tara Satterfield for tax year 2020 that would permit her to invoke this Court's jurisdiction. Respondent states in the motion to dismiss that petitioners do not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion to dismiss is granted in that so much of this case relating to petitioner Tara Satterfield for tax year 2020 is dismissed for lack of jurisdiction. Petitioners are reminded that so much of this case as relates to petitioner Phillip Cleary for tax year 2020 and petitioners Phillip Cleary and Tara Satterfield for tax year 2021 remains pending before the Court.