Opinion
32197-21S
09-20-2022
JOHN M. LUDGEY & RUNCAI LUDGEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On January 19, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency, no notice of determination concerning collection action, or any other notice of determination conferring jurisdiction on the Tax Court was issued to petitioners for tax year 2019 that would permit petitioners to invoke the Court's jurisdiction. On February 11, 2022, petitioners filed an opposition to respondent's motion. On September 19, 2022, respondent filed a supplement to his motion, in which he also seeks to dismiss tax year 2020 on the ground that no notice of deficiency, no notice of determination concerning collection action, or any other notice of determination conferring jurisdiction on the Tax Court was issued to petitioners for tax year 2020 that would permit petitioners to invoke the Court's jurisdiction. Respondent states in the supplement that petitioners do not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented, is granted and this case is dismissed for lack of jurisdiction.