Opinion
13684-21L
09-16-2021
John R. Cifelli Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On August 31, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to 2009; 2018; 2019. Therein, respondent moves that this case, insofar as it relates to the taxable years 2009, 2018, and 2019, be dismissed for lack of jurisdiction on the ground that the notice of determination in this case relates only to the taxable years 2014, 2015, and 2017, and no notice has been issued to petitioner that would confer jurisdiction on the Court with respect to the taxable years 2009, 2018, and 2019. In his motion respondent states that petitioner does not object to the granting thereof.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction as to 2009; 2018; 2019 is granted in that this case is dismissed for lack of jurisdiction as to the taxable years 2009, 2018, and 2019, and so much of this case relating to the 2009, 2018, and 2019 taxable years is deemed stricken from the Court's record in this case. Petitioner is advised that petitioner's claims with respect to the taxable years 2014, 2015, and 2017 remain pending before this Court.
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