Opinion
35531-21S
03-02-2022
Kevin R. Kunz & Anne M. Kunz Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Eunkyong Choi, Special Trial Judge
This case is presently calendared for trial at the Court's standalone remote session beginning on May 9, 2022. On February 25, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to taxable year 2019 upon the ground that because petitioners paid the proposed deficiency prior to the issuance of the notice of deficiency, no deficiency existed when the notice of deficiency was issued. The notice of deficiency was issued in error.. Upon due consideration, it is hereby
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction filed February 25, 2022, is granted and this case is dismissed for lack of jurisdiction.