Opinion
5511-22
02-27-2023
ORDER
Kathleen Kerrigan, Chief Judge
On May 6, 2022, respondent filed in the above docketed case a Motion To Dismiss for Lack of Jurisdiction and as to a notice of determination concerning collection action for the 2018 taxable year, on the ground that no notice of determination concerning collection action pursuant to section 6320 and/or 6330 of the Internal Revenue Code (I.R.C.) had been sent to petitioner with respect to the taxable year 2018, 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, petitioner has failed to do so.
Upon due consideration, it is
ORDERED that respondent's just referenced Motion To Dismiss For Lack of Jurisdiction and To Strike as to the Notice of Determination is granted. This case is dismissed for lack of jurisdiction as to any notice of determination concerning collection action for 2018, and references in the petition to such a notice are deemed stricken.