Opinion
30169-21S
08-15-2022
DEVPAL S. HAZARA & JEET KAUR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 13, 2022, petitioners filed the petition to commence this case, indicating that they seek review of a notice of deficiency and a notice of determination concerning collection action issued for their 2018 tax year. A notice of deficiency, dated June 21, 2021, issued to petitioners for their 2018 tax year is attached to the petition. Petitioners did not attach to the petition any notice of determination concerning collection action.
On August 10, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to a Notice of Determination Concerning Collection Action, asserting therein that so much of this case relating to a notice of determination concerning collection action for petitioners' 2016 and 2017 tax years should be dismissed as no such notice has been issued to petitioners that would permit them to invoke the jurisdiction of this Court. Petitioners, however, do not appear to have raised any issues in this case concerning their 2016 and 2017 tax years.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is denied.