Opinion
18222-22
02-01-2023
ASHLEY M. FUNK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On December 9, 2022, the parties filed a Joint Motion to Dismiss for Lack of Jurisdiction as to Taxable Years 2021 and 2022 and to Strike on the ground that no notice of deficiency, no notice of determination concerning collection action or any other notice of determination has been issued to petitioner for tax years 2021 or 2022 that would confer jurisdiction on this Court.
Upon due consideration, it is
ORDERED that the parties' above-referenced motion is granted in that so much of this case as relates to a notice of deficiency for tax years 2021 and 2022 is dismissed for lack of jurisdiction. Petitioner is reminded that so much of this case as relates to a notice of deficiency for tax year 2020 remains pending before the Court.