Opinion
14325-20S
12-09-2021
Beverly Etim Akpaudo Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On December 15, 2020, petitioner filed the petition to commence this case. In the petition, petitioner stated that she seeks review of a notice of deficiency issued for the 2020 tax year. However, petitioner attached to the petition a partial copy of a notice of deficiency issued for her 2018 tax year.
On October 20, 2021, the Court issued an Order to Show Cause, directing the parties to show cause why so much of this case relating to tax year 2020 should not be dismissed for lack of jurisdiction.
In response to the Court's Order, on October 27, 2021, respondent filed a motion to dismiss for lack of jurisdiction as to 2020 on the ground that no notice of deficiency or notice of determination for tax year 2020 was issued to petitioner sufficient to confer jurisdiction on this Court. Respondent states in his motion that petitioner has no objection to the granting of the motion.
Upon due consideration, it is
ORDERED that the Court's Order to Show Cause, issued October 20, 2021, is made absolute. It is further
ORDERED that respondent's motion to dismiss for lack of jurisdiction as to 2020 is granted and so much of this case relating to tax year 2020 is dismissed for lack of jurisdiction and deemed stricken from the Court's record. Petitioner is advised that her claims with respect to tax year 2018 remain pending before the Court.