Opinion
555-22S
04-18-2022
JANET ORDONEZ CANTADA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On January 18, 2022, petitioner filed the petition to commence this case, seeking to challenge a notice of deficiency issued for petitioner's 2019 tax year. On March 21, 2022, the Court issued an Order to Show Cause directing the parties to show cause why this case should not be dismissed on the ground that petitioner fully paid the tax liability for tax year 2019 before the notice of deficiency was issued and that, therefore, the notice of deficiency is invalid. On April 4, 2022, respondent filed a notice of no objection to this case being dismissed for the reasons stated in the Court's Order. No response has been received from petitioner.
Upon due consideration, it is ORDERED that the Court's Order to Show Cause, issued March 21, 2022, is made absolute. It is further
ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid.