Opinion
11457-22
03-15-2023
JESSICA LYNN JACOB & SETH JACOB, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On June 21, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Seth Jacob, 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 Seth Jacob with respect to taxable year 2017, nor had respondent made any other determination with respect to Seth Jacob's tax year 2017 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 Seth Jacob is granted. This case is dismissed for lack of jurisdiction as to Seth Jacob and references in the petition to Seth Jacob are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Jessica Lynn Jacob, Petitioner v. Commissioner of Internal Revenue, Respondent".