Opinion
3604-22S
11-28-2022
ABDUL RASHINE GRIER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
Pending before the Court is respondent's Motion to Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Relief From Joint and Several Liability Under Section 6015, filed April 21, 2022. By Order served July 7, 2022, the Court directed petitioner to file an objection, if any, to the Motion. To date, no such objection has been filed.
Accordingly, and for the reasons stated in respondent's Motion, it is
ORDERED that respondent's above-referenced Motion is granted, and so much of this case relating to a notice of determination concerning relief from joint and several liability under section 6015 (or the failure of the IRS to make such a determination within six months after an election or request for relief) is dismissed for lack of jurisdiction. All references to such a notice (or failure) are hereby deemed stricken from the Court's record in this case.
Petitioner is advised that so much of this case relating to the Notice of Deficiency issued to him for the taxable years 2018 and 2019 remains pending before the Court.