Opinion
30956-21S
11-09-2022
KENNY L. JACKSON & CATHY JACKSON, DECEASED, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 28, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to Cathy Jackson, Deceased and To Change Caption on the ground that no notice of deficiency or other notice of determination was issued to decedent or decedent's estate that would permit her to invoke the Court's jurisdiction. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss as to decedent, they failed to do so.
The premises considered, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted in that so much of this case relating to decedent is dismissed for lack of jurisdiction. It is further
ORDERED that the caption of this case is amended to read: "Kenny L. Jackson, Petitioner v. Commissioner of Internal Revenue, Respondent".