Opinion
10545-23S
08-23-2023
ROBYN FRANZA & BRAHM CASTAGLIOLA, Petitioners 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 Notice of Final Determination for Disallowance of Interest Abatement Claim, filed August 17, 2023, on the grounds that no such determination was issued to petitioners for their 2020 tax year sufficient to confer jurisdiction on this Court, and petitioners having no objection to respondent's just-described Motion, it is
ORDERED that respondent's above-described Motion is granted in that so much of this case relating to a notice of final determination for disallowance of interest abatement claim is dismissed for lack of jurisdiction and deemed stricken from the Court's record in this case. Petitioners are advised that so much of this case relating to the notice of deficiency issued for their 2020 tax year remains pending before the Court.