Opinion
2817-24S
05-31-2024
DOUGLAS A. LOCKE & ROBIN M. LOCKE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On April 12, 2024, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Petitioner Robin M. Locke and Motion to Amend Caption, 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 Robin M. Locke with respect to taxable year 2020, nor had respondent made any other determination with respect to Robin M. Locke'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 Petitioner Robin M. Locke and Motion to Amend Caption is granted. This case is dismissed for lack of jurisdiction as to Robin M. Locke, and references in the petition to Robin M. Locke are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Douglas A. Locke, Petitioner v. Commissioner of Internal Revenue, Respondent".