Opinion
8085-22S
07-21-2022
DANIEL A. CROWSON & BARBARA A. CROWSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On April 4, 2022, petitioners filed the petition to commence this case. Petitioners state in the petition that they seek review of a notice of deficiency issued to them for their 2019 tax year. The notice of deficiency, dated March 28, 2022, issued for petitioners' 2019 tax year is attached to the petition. In describing in the petition why they disagree with respondent's notice of deficiency for tax year 2019, petitioners reference their 2018 tax year.
On May 27, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to 2018 on the ground that no notice of deficiency or notice of determination sufficient to confer jurisdiction on this Court was issued to petitioners for tax year 2018. However, upon review of the petition, the Court concludes that petitioners reference tax year 2018 only to explain their position concerning their 2019 tax year. It appears to the Court that petitioners seek review in this case only with respect to their 2019 tax year.
Accordingly, upon due consideration of the foregoing, it is ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed May 27, 2022, is denied.