Opinion
11452-22S
03-15-2023
PAUL JAMES HOGAN & CAROLE ANN HOGAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On June 8, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Carol Ann Hogan, 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 Carol Ann Hogan with respect to taxable year 2018, nor had respondent made any other determination with respect to Carol Ann Hogan's tax year 2018 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 Carol Ann Hogan is granted. This case is dismissed for lack of jurisdiction as to Carol Ann Hogan, and references in the petition to Carol Ann Hogan are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Paul James Hoga, Petitioner v. Commissioner of Internal Revenue, Respondent".