Opinion
20864-22
03-14-2023
FRANCES E. MARCOU & RONALD L. MARCOU, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 18, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Petitioner Ronald Marcou, 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 Ronald Marcou with respect to taxable year 2018, nor had respondent made any other determination with respect to Ronald Marcou'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 Petitioner Ronald Marcou is granted. This case is dismissed for lack of jurisdiction as to Ronald L. Marcou, and references in the petition to Ronald L. Marcou are deemed stricken. It is further
ORDERED that the caption of this case is amended to read "Frances E. Marcou, Petitioner v. Commissioner of Internal Revenue, Respondent".