Opinion
3102-21
01-06-2022
Carly N. Little Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On April 9, 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. Although the Court directed petitioner to file an objection, if any, to respondent's motion, petitioner failed to do so.
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.