Opinion
3527-24
04-17-2024
WILLIAM M. COYNE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 4, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to and to Strike as to the Penalty and Purported Notice of Deficiency on the ground that no notice of deficiency has been issued to petitioner for tax year 2021 that would confer jurisdiction on this Court. Respondent states in the motion that petitioner does not object to the granting of the motion.
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 2021 is dismissed for lack of jurisdiction. Petitioner is reminded that so much of this case as relates to a Failure of IRS to Make Final Determination Within 180 Days After Claim for Abatement for tax year 2021 remains pending before the Court.