Opinion
13561-23S
12-05-2023
DONNELL J. FORD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion to Dismiss for Lack of Jurisdiction as to a Notice of Determination Concerning Collection Action, Notice of Final Determination for Disallowance of Interest Abatement Claim, and Notice of Determination of Worker Classification; there being no objection to the granting of that Motion; and for cause, it is
ORDERED that respondent's above-referenced Motion is recharacterized as respondent's Motion to Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Collection Action, Notice of Final Determination for Disallowance of Interest Abatement Claim, and Notice of Determination of Worker Classification, and as to Taxable Year 2021. It is further
ORDERED that respondent's just-referenced Motion is granted in that it is:
ORDERED that so much of this case relating to (1) a notice of determination concerning collection action, (2) a notice of final determination for disallowance of interest abatement claim (or the failure of the Internal Revenue Service to make a final determination within 180 days after a claim for such abatement), and (3) a notice of determination of worker classification, is dismissed for lack of jurisdiction. All references to such notices (or such failure) are deemed stricken from the Petition. It is further
ORDERED that this case is dismissed for lack of jurisdiction as to the taxable year 2021. All references in the Petition to the taxable year 2021 are deemed stricken.
Petitioner is advised that so much of this case relating to the notice of deficiency issued to petitioner for the taxable year 2022 remains pending before the Court.