Opinion
25232-21S
02-25-2022
Frank L. Laveaga & Rosalba L. Laveaga Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On December 1, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Collection Action and Notice of Final Determination Not to Abate Interest on the grounds that no notice of determination concerning collection action and no notice of final determination not to abate interest have been issued to petitioner for tax year 2019 that would confer jurisdiction on this Court. Respondent states in the motion to dismiss that petitioner does not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is granted in that so much of this case as relates to a notice of determination concerning collection action for tax year 2019 and so much of this case as relates to a notice of final determination not to abate interest for tax year 2019 is dismissed for lack of jurisdiction. Petitioner is reminded that so much of this case as relates to a notice of deficiency for tax year 2019 remains pending before the Court. 1