Opinion
12003-23L
10-19-2023
JOHN CRAWFORD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On September 8, 2023, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that no notice of determination pursuant to section 6320 and/or 6330 of the Internal Revenue Code (I.R.C.) had been sent to petitioner with respect to the taxable periods ending September 30, 2011; December 31, 2011; March 31, 2012; June 30, 2012; December 31, 2012; March 31, 2013; and June 30, 2013; nor had respondent made any other determination, including a notice of final determination for disallowance of interest abatement claim, with respect to such tax periods that would confer jurisdiction on this Court, as of the date the petition herein was filed. The motion further advised that there was no indication that petitioner had submitted to the Internal Revenue Service (IRS) a relevant claim for interest abatement as to which no determination had been made after an elapse of 180 days.
Subsequently, on October 10, 2023, petitioner filed a notice of no objection to the granting of the motion to dismiss for lack of jurisdiction.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted, and this case is dismissed for lack of jurisdiction.