Opinion
12218-22S
02-22-2023
WILLIAM H. MARKS & PATRICIA M. MARKS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy Special Trial Judge
This case is calendared for trial at the Tampa, Florida, trial session of the Court scheduled to commence on April 11, 2023.
On February 17, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Williiam H. Marks and to Change Caption. In the motion, respondent states that no notice of deficiency was issued to petitioner William H. Marks, and thus, the Court does not have jurisdiction over this petitioner's case for the specific taxable year at issue.
Upon due consideration of respondent's motion and for cause, it is
ORDERED that, on or before March 17, 2023, petitioners shall file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction as to Williiam H. Marks and to Change Caption, filed February 17, 2023. Failure to file an objection may result in the Court granting respondent's motion.
If petitioners believe a telephone conference call would be helpful, please contact Linda Thomas, at 202-521-0835, to schedule a conference call.
This Order constitutes official notice of its contents to the parties.