Opinion
27689-21
02-22-2022
Kam-Chuen Jim & Pen-Pen Chen Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge.
Upon due consideration of respondent's Motion to Dismiss for Lack of Jurisdiction, filed December 2, 2021, on the ground that petitioners paid the tax liability for tax year 2018 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency on which this case is based is invalid, and there appearing to be no objection to the granting of the motion, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid.