Opinion
15566-22L
12-07-2023
DON L. ROCKAFELLOR & KATHLEEN M. ROCKAFELLOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND DECISION
Travis A. Greaves Judge
Pursuant to the determination of this Court, as set forth in its Memorandum Opinion (T.C. Memo. 2023-137), filed November 14, 2023, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to Notices of Determination and Notice of Final Determination for Full/Partial Disallowance of Interest Abatement, filed February 22, 2023, is granted. It is further
ORDERED that respondent's Motion for Summary Judgment, filed March 3, 2023, is granted. It is further
ORDERED and DECIDED that respondent may proceed with collection as determined in the Notice of Determination, dated June 7, 2022, a copy of which is attached to the petition.