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Guerrero v. Comm'r of Internal Revenue

United States Tax Court
Mar 12, 2024
No. 2305-24S (U.S.T.C. Mar. 12, 2024)

Opinion

2305-24S

03-12-2024

EFRAIN FLORES GUERRERO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan, Chief Judge

On March 5, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Thereafter, on March 11, 2024, respondent filed a First Supplemental Motion to Dismiss for Lack of Jurisdiction.

In his motion, as supplemented, respondent asserts that (1) as to tax year 2021, this case should be dismissed for lack of jurisdiction on the grounds that the tax liability for 2021 was paid in full before the issuance of the notice of deficiency and thus the notice of deficiency for petitioner's 2021 tax year is invalid, and (2) as to tax years 2023 and 2024, no notice of deficiency was issued to petitioner, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court. Respondent represents that petitioner has no objection to the granting of his motion, as supplemented.

Upon due consideration of the foregoing, and for the reasons set forth in respondent's motion, as supplemented, it is

ORDERED that respondent's above-referenced motion, as supplemented, is granted and this case is dismissed for lack of jurisdiction.


Summaries of

Guerrero v. Comm'r of Internal Revenue

United States Tax Court
Mar 12, 2024
No. 2305-24S (U.S.T.C. Mar. 12, 2024)
Case details for

Guerrero v. Comm'r of Internal Revenue

Case Details

Full title:EFRAIN FLORES GUERRERO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Mar 12, 2024

Citations

No. 2305-24S (U.S.T.C. Mar. 12, 2024)