Opinion
26837-22
04-18-2023
RICHARD G. RICCARDI & AMANDA B. ERB, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On February 23, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency, no notice of determination concerning collection action, or any other notice of determination conferring jurisdiction on the Tax Court was issued to petitioners for tax years 2019 or 2020 that would permit petitioner to invoke the Court's jurisdiction. Respondent states in the motion that petitioners do not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction.