Opinion
5934-24
05-22-2024
LAURANCE D. BLACKBURN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On May 21, 2024, respondent electronically filed a document in this case, designating the filing as a Motion to Dismiss for Lack of Jurisdiction. However, the Motion only seeks to dismiss this case for lack of jurisdiction to the extent that the case seeks review of a notice of determination concerning relief from joint and several liability under I.R.C. section 6015 (or the failure of the Internal Revenue Service (IRS) to make such a determination within six months after an election or request for relief). There is no objection to the granting of the Motion. It is accordingly
ORDERED that respondent's above-referenced Motion is recharacterized as a Motion to Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Relief from Joint and Several Liability. It is further
ORDERED that respondent's just-referenced Motion is granted, and so much of this case relating to a notice of determination concerning relief from joint and several liability under I.R.C. section 6015 (or the failure of the IRS to make such a determination within six months after an election or request for relief) is dismissed for lack of jurisdiction. All references to such a notice (or failure) are deemed stricken from the Court's record in this case.
Petitioner is informed that so much of this case relating to the notice of deficiency issued to him for the taxable year 2021 remains pending before the Court.