Opinion
24659-21S
01-19-2022
Steven Robert Costa & Sharon Leigh Costa Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On November 16, 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 on which this case is based is invalid. In his motion to dismiss, respondent states 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 on which this case is based is invalid.