Opinion
17029-22S
09-27-2022
ROBERT T. KNIPE & LAUREN A. KNIPE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On August 3, 2022, petitioners filed the petition to commence this case, seeking review of notices of deficiency issued for their 2019 and 2020 tax year. On September 23, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Respondent asserts therein that so much of this case relating to tax year 2020 should be dismissed on the ground that no notice of deficiency or notice of determination sufficient to confer jurisdiction on this Court had been issued to petitioners for tax year 2020 as of the date of the filing of the petition. Respondent states that petitioners have no objection to the granting of the motion.
Upon due consideration, it is
ORDERED that the above-referenced motion is recharacterized as a Motion to Dismiss for Lack of Jurisdiction as to Tax Year 2020. It is further
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to Tax Year 2020 is granted in that so much this case of this case relating to tax year 2020 is dismissed for lack of jurisdiction and is deemed stricken from the Court's record.