Opinion
22217-21
11-12-2021
Estate of Martha S. Lovell, Deceased, Sara Carrington, Executrix Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On October 28, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that petitioner paid the tax liability for tax year 2018 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency is invalid. Respondent states in the motion to dismiss that petitioner does not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted in that this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.