Opinion
2368-24S
04-03-2024
BLAKE T. AHOLELEI & MANDY R. AHOLELEI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On March 28, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Year 2023 and to Strike on the ground that no notice of deficiency was issued to petitioners for tax year 2023, nor had respondent made any other determination with respect to 2023 that would confer jurisdiction on this Court. Respondent represents that petitioners do not object to the granting of this motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to the Taxable Year 2023 and to Strike is granted, and this case is dismissed for lack of jurisdiction as to the taxable year 2023. All references in the Petition to the taxable year 2023 are deemed stricken.
Petitioners are informed that their claims with respect to the notice of deficiency issued to them for the taxable year 2021 remain pending before the Court.