Opinion
9672-23
09-25-2023
ZAKARIA SHOOBLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE
On August 2, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction seeking to dismiss this case as to tax year 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 year 2023 that would confer jurisdiction on this Court. Respondent states in the motion to dismiss that petitioner does not object to the granting of the motion.
On August 17, 2023, respondent filed a supplement to his motion, in which he states that the Court has jurisdiction as to tax year 2021.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion, as supplemented, is granted in that so much of this case as relates to a notice of deficiency for tax year 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.