Opinion
3743-24
05-01-2024
JEREMY D. ALLEN & JENNIFER A. ALLEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On April 30, 2024, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, seeking dismissal of this case in part as to a purported Notice of Determination Concerning Relief From Joint and Several Liability Under Section 6015, on the ground that no such notice of determination pursuant to section 6015 of the Internal Revenue Code (I.R.C.) had been sent to petitioners with respect to the taxable year 2021, as of the date the petition herein was filed. In the motion, respondent indicated that petitioners had no objection to the granting thereof.
Upon due consideration, it is
ORDERED that respondent's motion filed April 30, 2024, at Docket Index No. 8, shall be recharacterized as a Motion To Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Relief From Joint and Several Liability Under Section 6015. It is further
ORDERED that respondent's just-referenced Motion To Dismiss For Lack of Jurisdiction Notice of Determination Concerning Relief From Joint and Several Liability Under Section 6015 is granted. This case is dismissed for lack of jurisdiction as to any Notice of Determination Concerning Relief From Joint and Several Liability Under Section 6015 action for 2021, and references in the petition to such a notice are deemed stricken.