Opinion
30332-21
08-29-2023
JONATHAN CASTILLO & ARELI J. CASTILLO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 3, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction seeking to dismiss this case as to tax year 2020 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 2020 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 is granted in that so much of this case as relates to a notice of deficiency for tax year 2020 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 2019 remains pending before the Court.