Opinion
6334-22S
07-07-2022
DAVID LEONARD DIESSELHORST & CAROLYN RICHAR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion to Dismiss for Lack of Jurisdiction, filed May 10, 2022; the record indicating that petitioners paid the federal income tax liability for the 2018 taxable year before the issuance of the Notice of Deficiency in this case, thus rendering that Notice invalid; and there being no objection to the granting of the Motion, it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction on the ground that the Notice of Deficiency is invalid. It is further
ORDERED that petitioners' Motion for Entry of Decision, filed April 9, 2022, is denied.