Opinion
12168-23
01-30-2024
CHRISTOPHER BAWCOM & CHRYSTAL E. BAWCOM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge.
The Petition in the above-docketed matter seeks review of a notice of deficiency issued to petitioners for taxable year 2019. On October 17, 2023, the parties jointly filed a Motion to Dismiss for Lack of Jurisdiction. On January 11, 2024, the parties filed a First Supplement to their joint Motion. The parties agree that the notice of deficiency underlying this case was "invalidly sent." In the absence of a valid notice of deficiency, we lack jurisdiction over this case. See §§ 6212 and 6213; Rule 13(a) and (c); Hallmark Rsch. Collective v. Commissioner, 159 T.C. 126, 139-40 (2022).
Accordingly, the premises considered, it is
ORDERED that the above-described Motion to Dismiss for Lack of Jurisdiction, as supplemented, is granted, and this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency underlying this case is invalid.