Clover v. Comm'r of Internal Revenue

Full title: Peter J. Clover Petitioner v. Commissioner of Internal Revenue Respondent

Court: United States Tax Court

Date published: Sep 17, 2021

No. 10925-21 (U.S.T.C. Sep. 17, 2021)

Opinion

10925-21

09-17-2021

Peter J. Clover Petitioner v. Commissioner of Internal Revenue Respondent

Maurice B. Foley, Chief Judge

ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Maurice B. Foley, Chief Judge

On July 21, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that petitioner paid the tax liability for tax year 2018 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency on which this case is based is invalid. Although the Court directed petitioner to file an objection, if any, to respondent's motion, to date no response has been received from petitioner.

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 on which this case is based is invalid.

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