Opinion
14769-21
03-16-2022
Stephen L. Houchin & Sandra K. Houchin Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On December 30, 2021, respondent filed in this case a Motion to Close on Ground of Duplication. Respondent asserts in his motion that this case is a duplicate of petitioners' case at Docket No. 5515-21 as, in both cases, petitioners filed the petitions in connection with a notice of deficiency issued with respect to petitioners' 2018 tax year. A stipulated decision was entered on September 13, 2021 in petitioners' case at Docket No. 5515-21. That decision is now final. Respondent further states in his motion that petitioners do not object to the granting of his motion.
In view of the foregoing, it is
ORDERED that respondent's above-described motion is granted in that this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency for 2018 does not provide a basis for petitioners to invoke the Court's jurisdiction in this action.