Opinion
13075-22S
03-31-2023
DIANE D. HOWELL & SAMUEL B. HOWELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
JAMES S. HALPERN JUDGE
On March 27, 2023, respondent moved in the above case, insofar as it relates to petitioner Samuel B. Howell's taxable year 2017, be dismissed for lack of jurisdiction 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 Samuel B. Howell with respect to taxable year 2017, nor has respondent made any other determination with respect to petitioner Samuel B. Howell's taxable year 2017 that would confer jurisdiction on this Court. Therefore, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to Samuel B. Howell is granted. It is further
ORDERED that the caption in this case is changed to read, "Diane D. Howell, Petitioner v. Commissioner of Internal Revenue, Respondent."