Opinion
11227-22
03-06-2023
ALAIN EDLY LAROCHE & DEANA DENISE WILLIAMS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On June 28, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Alain Edly Laroche, 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 Alain Edly Laroche with respect to taxable year 2018, nor had respondent made any other determination with respect to Alain Edly Laroche'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 Alain Edly Laroche is granted. This case is dismissed for lack of jurisdiction as to Alain Edly Laroche, and references in the petition to Alain Edly Laroche are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Deana Denise Williams, Petitioner v. Commissioner of Internal Revenue, Respondent".