Opinion
26889-22
03-01-2024
COREY RANDALL SULT & AMBER NICOLE SULT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Richard T. Morrison Judge
On February 2, 2024, respondent moved to dismiss this case for lack of jurisdiction as to Petitioner Amber Nicole Sult on the grounds 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, was sent to petitioner Amber Nicole Sult with respect to taxable year 2018, nor has respondent made any other determination with respect to petitioner Amber Nicole Sult's taxable year 2018 that would confer jurisdiction on this Court.
On February 2, 2024, respondent filed a Motion for Continuance.
On February 7, 2024, the Court ordered petitioners to file responses to the two aforementioned motions by February 20, 2024.
As of the date of this Order, no responses have been received by or on behalf of petitioners.
Upon due consideration, it is
ORDERED that respondent's February 2, 2024 Motion to Dismiss for Lack of Jurisdiction as to Petitioner Amber Nicole Sult's taxable year 2018 is granted. This case is dismissed for lack of jurisdiction as to petitioner Amber Nicole Sult, and references in the petition to Amber Nicole Sult are deemed stricken. It is further
ORDERED that the caption of this case is amended to: "Corey Randall Sult, Petitioner v. Commissioner of Internal Revenue, Respondent."
ORDERED that respondent's February 2, 2024 Motion for Continuance is granted and this case is continued generally.