Opinion
12556-24
11-04-2024
SHANNON JENKINS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 1, 2024, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction as to (and to Strike) a Notice of Final Determination for Disallowance of Interest Abatement Claim, Notice of Determination Concerning Relief from Joint and Several Liability Under Section 6015, and Notice of Certification of Your Seriously Delinquent Federal Tax Debt to the Department of State on the ground that none of the above-named notices were sent to petitioner with respect to tax year 2021. Although the Court directed petitioner to file an objection, if any, to respondent's motion, petitioner did not do so.
Upon due consideration and for cause, it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction as to a Notice of Final Determination for Disallowance of Interest Abatement Claim, Notice of Determination Concerning Relief from Joint and Several Liability Under Section 6015, and Notice of Certification of Your Seriously Delinquent Federal Tax Debt to the Department of State. All references in the Petition to these notices are deemed stricken.
Petitioner is reminded that this case will continue as to the notice of deficiency issued with respect to her 2021 tax year.