Opinion
12370-22S
03-30-2023
MICHAEL J. MAHONEY & JAMES M. MAHONEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
James S. Halpern Judge
On March 27, 2023, respondent moved in the above case, insofar as it relates to the tax liability of petitioner James M. Mahoney's taxable year 2019, be dismissed for lack of jurisdiction upon the ground that no statutory notice of deficiency, as authorized by I.R.C. § 6212 and required by I.R.C. § 6213(a) to form the basis for a petition to this Court, has been sent to petitioner James M. Mahoney with respect to taxable year 2019, nor has respondent made any other determination with respect to petitioner James M. Mahoney's taxable year 2019 that would confer jurisdiction on this Court. Therefore, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to James M. Mahoney is granted. It is further
ORDERED that the caption in this case is changed to read, "Michael J. Mahoney, Petitioner v. Commissioner of Internal Revenue, Respondent."