Opinion
5657-23
08-08-2023
SYDNEY MITCHELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 3, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Years 2022 and 2023 seeking to dismiss this case as to tax years 2022 and 2023 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 petitioner for tax years 2022 and 2023 that would confer jurisdiction on this Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so.
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 2022 and 2023 is dismissed for lack of jurisdiction. Petitioner is reminded that so much of this case as relates to a notice of deficiency for tax year 2021 remains pending before the Court.