Opinion
15037-21S
04-07-2023
SUZANNE C. EMMEL, DECEASED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Adam B. Landy Special Trial Judge
On February 14, 2023, the Court ordered Drew Emmel, on behalf of Suzanne C. Emmel, Deceased, and the Commissioner to show cause in writing, on or before March 6, 2023, why the Court should not dismiss Ms. Emmel as a petitioner for lack of jurisdiction. The Court has received no such response or objection from Drew Emmel or additional heirs-at-law, Gregg R. Emmel and Todd Daniel Emmel.
Upon due consideration and for cause, it is
ORDERED that the Order to Show Cause, served February 14, 2023, is made absolute, and Suzanne C. Emmel, Deceased is dismissed as petitioner for lack of jurisdiction. It is further
ORDERED that the Commissioner's Motion to Dismiss for Lack of Prosecution, filed January 31, 2023, and as supplemented February 10, 2023, is denied as moot. It is further
ORDERED that, in addition to regular service on the parties, the Clerk of the Court shall serve this Order of Dismissal for Lack of Jurisdiction on Drew Emmel, Gregg R. Emmel, and Todd Daniel Emmel at the addresses listed on the certificate of service attached to the Commissioner's motion, filed January 31, 2023, and as supplemented February 10, 2023.