Opinion
5411-21
03-17-2022
Ilana Jivago Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On June 16, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground no notice of deficiency was issued to petitioner for tax years 2016 and 2017 that would permit petitioner to invoke the Court's jurisdiction in this case. On March 15, 2022, respondent filed a Status Report. Among other things, in his Report respondent now acknowledges that: (1) a notice of deficiency dated November 2, 2020, was issued to petitioner for 2016 and 2017; (2) the petition in this case was filed timely as to that deficiency notice; and (3) respondent's above motion to dismiss should be denied. Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction, filed June 16, 2021, is denied.