Opinion
18228-22
03-31-2023
SHAFAQ JALEES KHAN & USMAN ARIF ARAIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 23, 2023, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Usman Arif Arian, 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 Usman Arif Arian with respect to taxable year 2020, nor had respondent made any other determination with respect to Usman Arif Arian's tax year 2020 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 Usman Arif Arian is granted. This case is dismissed for lack of jurisdiction as to Usman Arif Arian, and references in the petition to Usman Arif Arian are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Shafaq Jalees Khan, Petitioner v. Commissioner of Internal Revenue, Respondent".