Opinion
7427-23
08-03-2023
ANDREW W. ODELL & SARA A. ODELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 2, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Andrew W. Odell and to Change Caption seeking to dismiss so much of this case relating to Andrew W. Odell on the ground that Andrew W. Odell did not file a petition with this Court and petitioner Sara A. Odell did not file a petition on behalf of Andrew W. Odell. Respondent also seeks to dismiss so much of this case as relates to a notice of determination concerning your request for relief from joint and several liability on the ground that no notice of determination of relief from joint and several liability has been sent to petitioners. Respondent states in the motion that petitioners do not object to the granting of this motion.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion to dismiss is granted in that so much of this case relating to Andrew W. Odell is dismissed for lack of jurisdiction and so much of this case as relates to a notice of determination of relief from joint and several liability is dismissed for lack of jurisdiction. It is further
ORDERED that the caption in this case is amended to read: "Sara A. Odell, Petitioner v. Commissioner of Internal Revenue, Respondent".
Petitioner Sara A. Odell is reminded that so much of this case as relates to a notice of deficiency for tax year 2020 remains pending before the Court.