Opinion
7684-21S
12-21-2021
Juan C. Reynoso & Awilda G. Batista Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge.
The petition filed to commence this case did not bear the original signature of petitioner Juan C. Reynoso. By Order issued May 19, 2021, he was directed to file a Ratification of Petition on or before July 6, 2021. He did not comply with the Court's Order.
On July 7, 2021, respondent filed a motion to dismiss petitioner Awilda G. Batista for lack of jurisdiction on the ground no notice sufficient to confer jurisdiction upon the Court in this case was issued to her. By Order issued August 2, 2021, petitioners were directed to file an objection, if any, to that motion. Petitioners failed to submit a response.
Upon due consideration of the record of this case and for cause, it is
ORDERED that the Court's Order to Show Cause issued May 19, 2021, is hereby made absolute and the docket number of this case is amended by deleting the letter "S" therefrom. The Clerk of the Court is hereafter directed to process this case as a regular tax case. It is further
ORDERED respondent's motion is granted, and so much of this case as pertains to petitioner Awilda G. Batista is dismissed for lack of jurisdiction. It is further
ORDERED that, on the Court's own motion, so much of this case as pertains to petitioner Juan C. Reynoso is dismissed for lack of jurisdiction on the ground he failed to ratify the petition. The Court, on its own motion, will consider reinstating the case if the petition is ratified by petitioner Juan C. Reynoso within 30 days from the date of service of this Order.