Opinion
15897-22S
12-22-2022
JESSICA AHN GANSS & PATRICK M. CARAHER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 8, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Years 2020, 2021, and 2022 on the ground that no notice of deficiency, no notice of determination concerning collection action or any other notice of determination has been issued to petitioners for tax years 2020, 2021, and 2022 that would confer jurisdiction on this Court. On August 10, 2022, respondent filed a Status Report, in which he states that petitioners do not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is granted in that so much of this case as relates to a notice of deficiency for tax years 2020, 2021, and 2022 is dismissed for lack of jurisdiction. Petitioners are reminded that so much of this case as relates to a notice of deficiency for tax year 2019 remains pending before the Court.