Opinion
15147-23S
04-11-2024
FELICIA COLEY & KEVIN SAVOY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On February 21, 2024, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Petitioner Kevin Savoy 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 Kevin Savoy with respect to taxable year 2021, nor had respondent made any other determination with respect to Kevin Savoy's tax year 2021 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 Petitioner Kevin Savoy and To Change Caption is granted. This case is dismissed for lack of jurisdiction as to Kevin Savoy, and references in the petition to Kevin Savoy are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Felicia Coley, Petitioner v. Commissioner of Internal Revenue, Respondent".