Opinion
15759-23
01-16-2024
WAYNE A. WORTHINGTON & JANE A. WORTHINGTON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 11, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Petitioner Jane A. Worthington (motion to dismiss). As grounds for his motionk respondent asserts that no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to Ms. Worthington's 2020 and 2021 tax years. Respondent indicates that Ms. Worthington does not object to the granting of his motion. Notwithstanding that representation, however, the Court will provide petitioners the opportunity to file an objection to respondent's motion to dismiss.
Upon due consideration, it is
ORDERED that, on or before February 7, 2024, petitioners shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to petitioner Jane A. Worthington.