Opinion
11732-22
01-12-2023
DAN HOWLAND SEARLE III & CAROLINE SEARLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On August 29, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Caroline Searle on the ground that no notice of deficiency was issued to petitioner Caroline Searle for tax year 2018 that would permit her to invoke this Court's jurisdiction. Respondent states in the motion to dismiss that petitioners do not object to the granting of the 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 Caroline Searle is dismissed for lack of jurisdiction. It is further
ORDERED that the caption in this case is amended to read: "Dan Howland Searle, III, Petitioner v. Commissioner of Internal Revenue, Respondent".