Opinion
17056-23
12-12-2023
MARIA G. BELLIZZI & ROBERT AMBROSIO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
KATHLEEN KERRIGAN CHIEF JUDGE.
Upon due consideration of respondent's Motion to Dismiss for Lack of Jurisdiction, filed December 8, 2023, on the grounds that that there is no deficiency in income tax due from petitioners for taxable year 2021 as defined by Internal Revenue Code § 6211 and thus the notice of deficiency on which this case is based was not authorized by I.R.C. § 6212, and petitioners having no objection to the granting of respondent's motion, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid.