Opinion
17527-21S
09-17-2021
Moamer A. Hassan & Intath Alharbi Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On September 13, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Collection Action and Notice of Final Determination for Full / Partial Disallowance of Interest Abatement Claim on the grounds that no notice of determination concerning collection action or notice of final determination for full / partial disallowance of interest abatement claim has been issued to petitioners for tax year 2019 that would confer jurisdiction on this Court. Respondent states in the motion to dismiss 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 determination concerning collection action for tax year 2019 and so much of this case as relates to a notice of final determination for full / partial disallowance of interest abatement claim for tax year 2019 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.
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