Opinion
14695-21
07-26-2022
MICHAEL J. HALLORAN & MARSHA CAMERON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On June 7, 2022, the parties filed a proposed stipulated decision for the Court's consideration. Upon further review of the record, on June 16, 2022, the Court issued an Order to Show Cause directing the parties to show cause why this case should not be dismissed on the ground that petitioners paid the deficiency for tax year 2018 prior to the issuance of the notice of deficiency, and, therefore, the notice of deficiency on which this case is based is invalid. On July 8, 2022, respondent filed a response to the Court's Order to Show Cause in which respondent asserts that this case should be dismissed on the ground that the notice of deficiency issued to petitioners for their 2018 tax year is invalid. The Court has received no response from petitioners.
Upon due consideration, it is ORDERED that the Court's Order to Show Cause, issued June 16, 2022, is made absolute. It is further
ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid. It is further
ORDERED that the above-referenced proposed stipulated decision is stricken from the Court's record.