Opinion
16560-22
09-28-2022
JAMISON P. LAMBRELLI & LAURA WALTERS, A.K.A. LAURA LAMBRELLI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
KATHLEEN KERRIGAN, CHIEF JUDGE
On September 15, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the purported notice of deficiency dated June 13, 2022, issued to petitioners with respect to the taxable year 2019 and upon which this case is based, is invalid. To wit, respondent explained that the just-referenced notice was an invalid second notice under section 6212(c) of the Internal Revenue Code. Respondent further indicated that petitioners had 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 on the ground that the purported notice of deficiency dated June 13, 2022, is invalid.