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Thomas v. Comm'r of Internal Revenue

United States Tax Court
Mar 21, 2023
No. 25376-22 (U.S.T.C. Mar. 21, 2023)

Opinion

25376-22

03-21-2023

JIMMY THOMAS & DWAINE THOMAS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On November 14, 2022, the Court received from petitioners a letter, attached to which was a copy of a notice of deficiency dated October 31, 2021, issued to petitioners with respect to the 2020 taxable year. To protect petitioners' statutory time period within which to begin a case, the Court filed that letter as a petition to commence this case at Docket No. 25376-22. On December 6 and 15, 2022, the Court issued Order directing the filing of a Ratification of Petition by Jimmy Thomas and payment of the filing fee for this litigation. On January 9, 2023, the Court then received from petitioners a further letter indicating that petitioners did not intend by the initial correspondence with this Court to begin a case herein and that petitioners preferred to work administratively through the Internal Revenue Service to resolve the 2020 tax matters, rather than to continue with the instant Court proceeding. Accordingly, it appearing that petitioners do not intend to file a Ratification of Petition and pay the filing fee as directed in the Court's Orders, it is

ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction. It is further

ORDERED that the copy of petitioners' January 9, 2023, letter duplicatively filed as a Motion for Entry of Decision at Docket Entry #7 is hereby deemed stricken from the Court's record in this case.


Summaries of

Thomas v. Comm'r of Internal Revenue

United States Tax Court
Mar 21, 2023
No. 25376-22 (U.S.T.C. Mar. 21, 2023)
Case details for

Thomas v. Comm'r of Internal Revenue

Case Details

Full title:JIMMY THOMAS & DWAINE THOMAS, Petitioners v. COMMISSIONER OF INTERNAL…

Court:United States Tax Court

Date published: Mar 21, 2023

Citations

No. 25376-22 (U.S.T.C. Mar. 21, 2023)