Opinion
3752-23
02-15-2024
BRENT HAWKINS & CATHERINE HAWKINS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge.
Petitioners, through counsel, filed their Petition on February 21, 2023. The Court calendared this case for trial in Nashville, Tennessee beginning on April 8, 2024. On February 14, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to petitioner-wife Catherine Hawkins upon the ground that no statutory notice of deficiency, as authorized by I.R.C. § 6212 and required by I.R.C. § 6213(a) to form the basis for a petition to this Court, has been sent to petitioner Catherine Hawkins with respect to taxable year 2019, nor has respondent made any other determination with respect to petitioner Catherine Hawkin's taxable year 2019 that would confer jurisdiction on this Court. The motion also states that respondent's counsel attempted to contact petitioners' counsel without success.
Accordingly, it is
ORDERED that on or before March 8, 2024, petitioners shall file a response as to why the Court should not grant respondent's above-referenced motion to dismiss.