Opinion
12586-20
06-25-2021
Rocky E. Griffith & Sharon R. Griffith Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On March 2, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to Notice of Determination. In his motion to dismiss as to collection action respondent moves to dismiss for lack of jurisdiction so much of this case relating to the notice of determination concerning collection action on the ground no notice of determination under I.R.C. section 6320 or 6330 was issued with respect to petitioners' tax years 2010 through 2016. Although the Court directed petitioners to file an Objection, if any, to respondent's motion to dismiss as to collection action, petitioners failed to do so. Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted in that so much of this case relating to the notice of determination concerning collection action for 2010 through 2016 is dismissed for lack of jurisdiction.