Opinion
17053-22
06-08-2023
PHIRUN SAO & PHIRUM SNGIEM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Juan F. Vasquez Judge
On May 3, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Phirum Sngiem upon the ground that no statutory notice of deficiency, as authorized by I.R.C. § 6212 and required by I.R.C. § 6213(a) to form the basis for a petition to this Court, has been sent to Phirum Sngiem with respect to taxable year 2019, nor has respondent made any other determination with respect to Phirum Sngiem's taxable year 2019 that would confer jurisdiction on this Court. Respondent states in the motion that petitioners have no objection to the granting of the motion.
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced motion is granted and so much of this case relating to petitioner Phirum Sngiem is dismissed and is deemed stricken from the Court's record. It is further
ORDERED that the caption of this case is amended to read: "Phirun Sao, Petitioner v. Commissioner of Internal Revenue, Respondent".