Opinion
10349-21S
12-09-2021
Xiang Dong Chen Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On July 26, 2021, respondent filed a motion to dismiss for lack of jurisdiction as to notice of determination concerning collection action for tax year 2019 and to strike. Respondent asserts in his motion that no notice of determination concerning collection action for tax year 2019 was issued to petitioner that would permit petitioner to invoke the jurisdiction of this Court as to such notice. Although the Court directed petitioner to file an objection, if any, to respondent's motion, petitioner has not done so.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is granted and so much of this case relating to a notice of determination concerning collection action for tax year 2019 is dismissed for lack of jurisdiction and deemed stricken from the Court's record. Petitioner is advised that petitioner's claims with respect to a notice of deficiency issued for petitioner's 2019 tax year remain pending before the Court.