Opinion
22654-22
03-28-2023
COURTENEY ELEANOR DOERSCHEL & OSAMA ABDELDAYEM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On December 16, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Osama Abdeldayem, 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 Osama Abdeldayem with respect to taxable year 2020, nor had respondent made any other determination with respect to Osama Abdeldayem's tax year 2020 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 Osama Abdeldayem is granted. This case is dismissed for lack of jurisdiction as to Osama Abdeldayem, and references in the petition to Osama Abdeldayem are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Courteney Eleanor Doerschel, Petitioner v. Commissioner of Internal Revenue, Respondent".