Opinion
15024-21S
09-22-2021
John M. Gutowski & Edward Brown Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On September 7, 2021, respondent filed a motion to dismiss for lack of jurisdiction on the ground that petitioners paid the tax liability for the 2018 taxable year before the issuance of the notice of deficiency in this case, and the notice is therefore invalid. Respondent states in the motion that petitioners do not object to the granting of respondent's motion.
Upon due consideration and for cause, it is
ORDERED that respondent's motion to dismiss for lack of jurisdiction is granted in that this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.
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