Opinion
7394-24
07-01-2024
JOHN PAUL DEGONIA & KIMBERLY DALE DEGONIA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On June 28, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that petitioners had paid in full their federal income tax liability for the 2021 taxable year before the issuance of the notice of deficiency upon which this case is based, thereby rendering that notice invalid. Petitioners do not object to the granting of the Motion to Dismiss.
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.