Opinion
12087-20L
08-03-2022
CAROL MAHR BESORE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On February 9, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction. In the motion, respondent seeks to dismiss this case as to tax years 2010, 2011, 2012, 2013, and 2018 on the ground that no notice of deficiency, no notice of determination concerning collection action, or any other notice of determination has been issued to petitioner for tax years 2010, 2011, 2012, 2013, or 2018 that would confer jurisdiction on this Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is granted in that so much of this case as relates to a notice of determination concerning collection action for tax years 2010, 2011, 2012, 2013, and 2018 is dismissed for lack of jurisdiction. Petitioner is reminded that so much of this case as relates to a notice of deficiency for tax year 2009, 2014, 2015, 2016, and 2017 remains pending before the Court.