Opinion
3404-20L
11-04-2021
Paul Brian Fitzpatrick & Shelly Fitzpatrick Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On October 1, 2021, respondent filed a status report. Therein, respondent advises the Court that petitioners both apparently died at some point after filing the petition in this case.
In accordance with the principles established in Nordstrom v. Commissioner, 50 T.C. 30 (1968), the Court must give proper notice of this proceeding to the heirs at law of petitioners and afford them an opportunity to take whatever action may be necessary to protect their interests.
The foregoing considered, it is
ORDERED that the caption of this case is amended to read: "Paul Brian Fitzgerald, Deceased & Shelly Fitzgerald, Deceased, Petitioners v. Commissioner of Internal Revenue, Respondent". It is further
ORDERED that, on or before January 3, 2022, respondent shall file a report setting forth, based upon a diligent search conducted by respondent, and with respect to each decedent petitioner, the names, mailing addresses, and telephone numbers of any heirs at law of the decedent petitioner, whether administration of an estate has been opened for the decedent petitioner, and whether any person has been appointed as the executor, personal representative, or fiduciary for such estate. Respondent shall also attach to the report a copy of each decedent petitioner's death certificate.