Opinion
17357-22S
01-30-2023
ALIREZA ZARAFSHANI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 30, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to taxable year 2022 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 2022 that would confer jurisdiction on this Court. Respondent states in the motion that petitioner does not object to the granting of the motion.
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 year 2022 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 2019 remains pending before the Court.