Opinion
19231-23
11-01-2024
JEFFREY A. LEVY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
This case is based upon a notice of deficiency issued to petitioner Jeffrey A. Levy on September 11, 2023, determining a deficiency in his federal income tax for the taxable year 2021. However, the Court has been advised that Mr. Levy died on September 30, 2024, after filing the Petition to commence this case.
In accordance with the principles established in Nordstrom v. Commissioner, 50 T.C. 30 (1968), this Court must give proper notice of this proceeding to the heirs at law of the decedent and afford them an opportunity to take whatever action may be necessary to protect their interests.
Upon due consideration of the foregoing, it is
ORDERED that the caption of this case is amended to read: "Jeffrey A. Levy, Deceased, Petitioner v. Commissioner of Internal Revenue, Respondent." It is further
ORDERED that, on or before January 6, 2025, respondent shall file a report setting forth, based upon and following a reasonably diligent and good faith search conducted by respondent, the names, mailing addresses, and telephone numbers of the heirs at law of the decedent Jeffrey A. Levy. Respondent shall attach to such report a copy of the decedent's death certificate.