Opinion
12264-20S
01-04-2022
Ronald E. Ferguson & Jacqueline Ferguson Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration of respondent's Motion To Dismiss for Lack of Jurisdiction as to Alleged Notice of Determination Concerning Collection Action for Years 2016 and 2017 and To Strike, filed May 27, 2021, and for cause it is
ORDERED that the above-referenced motion is granted in that so much of this case as pertains to a notice of determination for petitioners' taxable years 2016 and 2017 is dismissed for lack of jurisdiction and deemed stricken.