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Proctor v. Comm'r of Internal Revenue

United States Tax Court
Aug 3, 2022
No. 12860-22S (U.S.T.C. Aug. 3, 2022)

Opinion

12860-22S

08-03-2022

DAVID WILLIAM PROCTOR & CYNTHIA LYNN PROCTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge

On July 8, 2022, the Court received from petitioner in the above-docketed matter a letter requesting that the instant proceeding be closed. In support of such request, petitioners advised that the underlying 2018 taxes had been resolved with the Internal Revenue Service (IRS) through payment. Review of the record herein, however, suggests that the basis for any closure of the case may be different as to the two petitioners, insofar as jurisdictional questions are raised with respect to petitioner Cynthia Lynn Proctor.

Accordingly, to clarify and to ensure appropriate treatment as to each petitioner, it is

ORDERED that, on or before August 23, 2022, respondent shall file either: (1) An appropriate jurisdictional motion as to Cynthia Lynn Proctor; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Cynthia Lynn Proctor and attaching thereto a copy of any supporting documentation.


Summaries of

Proctor v. Comm'r of Internal Revenue

United States Tax Court
Aug 3, 2022
No. 12860-22S (U.S.T.C. Aug. 3, 2022)
Case details for

Proctor v. Comm'r of Internal Revenue

Case Details

Full title:DAVID WILLIAM PROCTOR & CYNTHIA LYNN PROCTOR, Petitioners v. COMMISSIONER…

Court:United States Tax Court

Date published: Aug 3, 2022

Citations

No. 12860-22S (U.S.T.C. Aug. 3, 2022)