Opinion
23558-22S
03-27-2023
STEVEN JAN CZURAK & TRACY LYNN CZURAK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On December 23, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that no Notice of Certification of Your Seriously Delinquent Federal Tax Debt to the State Department had been sent to petitioners with respect to the taxable years 2019 or 2022, nor had respondent made any other determination with respect to such tax years that would confer jurisdiction on this Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so.
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.