Opinion
12557-23
12-21-2023
LINDA WORSHAM & IRA WORSHAM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 6, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction, in which he seeks to dismiss so much of this case as purports to be an appeal by Ira Worsham on the ground that no notice of deficiency and no notice of determination was issued to petitioner Ira Worsham for tax years 2012, 2013, 2014, or 2016 that would permit him to invoke this Court's jurisdiction. In respondent's motion, he also seeks to dismiss so much of this case as purports to be an appeal of a notice of deficiency issued to petitioner Linda Worsham for tax years 2012, 2013, 2014, or 2016 or a notice of determination issued to petitioner Linda Worsham for tax year 2012 on the ground that no such notices were issued to petitioner Linda Worsham. On December 13, 2023, petitioners filed a response to respondent's motion.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion to dismiss is granted in that: (1) so much of this case relating to Ira Worsham is dismissed for lack of jurisdiction, (2) so much of this case relating to tax year 2012 is dismissed for lack of jurisdiction, and (3) so much of this case related to a notice of deficiency for tax years 2013, 2014, and 2016 is dismissed for lack of jurisdiction. Petitioner Linda Worsham is reminded that so much of this case as relates to notices of determination concerning relief from joint and several liability for tax years 2013, 2014, and 2016 remains pending before the Court. It is further
ORDERED that the caption in this case is amended to read: "Linda Worsham, Petitioner v. Commissioner of Internal Revenue, Respondent".