Opinion
13426-21
08-25-2021
Paul A. Chovanec & Lori A. Chovanec Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On August 24, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that petitioners paid the tax liability for tax year 2018 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency is invalid. In his motion to dismiss respondent indicates that petitioners do not object to the granting of the motion. Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.