Opinion
33978-21
04-14-2022
PEDRO A. MACEDO & NICHOL B. LUCIDO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge.
On January 27, 2022, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds 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 2018 and 2019, nor had respondent made any other determination with respect to petitioners' tax years 2018 and 2019 that would confer jurisdiction on the Court, as of the date the petition herein was filed. In the motion, respondent indicated that petitioners had no objection to the granting thereof, and petitioners have subsequently filed a timely proceeding at Docket No. 4189-22.
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. 1