Opinion
35389-21S
04-22-2022
MARGARET SAADI KRAMER & WAYNE KRAMER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration of respondent's motion to dismiss for lack of jurisdiction, filed February 25, 2022, on the ground that no notice of determination concerning collection action and no notice of certification of your seriously delinquent Federal tax debt to the Department of State for tax years 2017 and 2018 were issued to petitioners, petitioners having no objection to the granting of that motion, it is
ORDERED that respondent's motion to dismiss for lack of jurisdiction is recharacterized as a motion to dismiss for lack of jurisdiction as to a notice of determination concerning collection action and a notice of certification of your seriously delinquent Federal tax debt to the Department of State for tax years 2017 and 2018. It is further
ORDERED that respondent's above-referenced motion is granted and so much of this case relating to a notice of determination concerning collection action and a notice of certification of your seriously delinquent Federal tax debt to the Department of State for tax years 2017 and 2018 is dismissed for lack of jurisdiction.