Opinion
32610-21
03-28-2022
Bruce Wetmore Lage & Linda K. Lage Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge.
On December 16, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Years 2019 and 2021 and To Strike, on the ground that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioners with respect to taxable years 2019 and 2021, nor had respondent made any other determination with respect to petitioners' tax year 2019 and 2021 that would confer jurisdiction on the Court, as of the date the petition herein was filed. In the motion, respondent further indicated that petitioners had no objection to the granting thereof.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction as to the Taxable Years 2019 and 2021 and To Strike is granted, and this case is dismissed for lack of jurisdiction as to taxable years 2019 and 2021. References to those years in the petition are deemed stricken.