Opinion
10989-22
02-21-2023
ROBERTO LUPI & LISA MARIE LUPI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 18, 2023, the parties filed a Proposed Stipulated Decision relating to petitioners' 2017, 2018, and 2019 tax years. Upon review, on February 7, 2023, the Court issued an Order to Show Cause, directing the parties to show cause why so much of this case relating to 2017 should not be dismissed for lack of jurisdiction as the Commissioner had not determined any deficiency for that tax year in the notice of deficiency on which this case is based. On February 14, 2023, the parties filed a Response to the Court's Order to Show Cause, agreeing therein that so much of this case relating to 2017 should be dismissed for lack of jurisdiction.
Upon due consideration of the foregoing, it is
ORDERED that the Court's Order to Show Cause, issued February 7, 2023, is made absolute. It is further
ORDERED that so much of this case relating to petitioners' 2017 tax year is dismissed for lack of jurisdiction. It is further
ORDERED that the parties' Proposed Stipulated Decision, filed January 18, 2023, is deemed stricken from the Court's record in this case.