Opinion
18223-23
12-07-2023
EDWARD J. DISTLER & LOUISE DISTLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On November 15, 2023, the Court received from petitioners a letter, attached to which was a copy of a notice of deficiency dated October 2, 2023, issued to petitioners with respect to the 2021 taxable year. To protect petitioners' statutory time period within which to begin a case, the Court filed that letter as a petition to commence this case at Docket No. 18223-23. On November 20 and 30, 2023, the Court issued Orders directing the filing of a Ratification of Petition and payment of the filing fee for this litigation. On December 5, 2023, the Court then received from petitioners a further letter indicating that petitioners preferred to work administratively through the Internal Revenue Service to resolve the 2021 tax matters through payment, rather than to continue with the instant Court proceeding. Accordingly, it appearing that petitioners do not intend to file a Ratification of Petition and pay the filing fee as directed in the Court's Orders, it is
ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction.