Opinion
5442-20
06-09-2021
Robert Carlile & Janet Carlile Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On September 30, 2020, respondent filed a Motion To Dismiss for Lack of Jurisdiction. On October 13, 2020, respondent filed a supplement to his motion. In his motion, as supplemented, respondent seeks to dismiss so much of this case as relates to a notice of deficiency for tax year 2017 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 petitioners for tax year 2017 that would confer jurisdiction on this Court. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners failed to do so.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion, as supplemented, is granted in that so much of this case as relates to a notice of deficiency for tax year 2017 is dismissed for lack of jurisdiction. Petitioners are reminded that so much of this case as relates to a notice of deficiency for tax year 2016 remains pending before the Court.