Opinion
4857-21S
06-21-2021
Joi C. Mackall Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On June 14, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to a Notice of Determination Concerning Collection Action and a Notice of Determination Concerning Relief from Joint and Several Liability on the ground that no notice of determination concerning collection action has been issued to petitioner for tax year 2018 and no notice of determination concerning relief from joint and several liability has been issued to petitioner for tax year 2018 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 2018 and so much of this case as relates to a notice of determination concerning relief from joint and several liability for tax year 2018 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 2018 remains pending before the Court.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you currently file in paper and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov.