Richard A. Wilson and Sharon L. Wilson v. Commissioner of Internal Revenue

The Commissioner of Internal Revenue disapproved certain adjustments made in respect to partnership income for the tax year 1972 and issued deficiency notices for that year. The appellants, who are individual taxpayers in the partnership, then filed a single, joint petition in the Tax Court challenging that determination. Ten Does were also named as petitioners. Upon the Commissioner’s motion, the Tax Court dismissed the Does for lack of jurisdiction and struck a paragraph in the petition relating to unnamed persons not before the court. The appellants appeal those orders. We dismiss the…