Opinion
26325-22S
03-24-2023
NIEL KRIVONAK & KATSUMI HARASHIMA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On February 9, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that no notice of deficiency was issued to petitioners, nor has respondent made any other determination, concerning petitioners' 2020 tax year that would permit petitioners to invoke the jurisdiction of this Court. Respondent further states that petitioners have no objection to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction.