Opinion
760-20L
09-07-2021
Jerry R. Abraham & Debra J. Abraham Petitioners v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
Patrick J. Urda Judge.
Pursuant to the determination of the Court as set forth in its Memorandum Opinion (T.C. Memo. 2021-97), filed August 3, 2021, it is hereby
ORDERED that this case as it relates to the 2017 taxable year is dismissed for lack of jurisdiction. It is further
ORDERED that respondent's motion for summary judgment, filed on August 20, 2020, is granted. It is further
ORDERED AND DECIDED that respondent may proceed with the collection action as determined in the Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 of the Internal Revenue Code, dated December 12, 2019, upon which this case this is based, with respect to petitioners' tax periods ending December 31, 2012, December 31, 2013, December 31, 2014, December 31, 2015, and December 31, 2016.
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