Opinion
8256-24L
07-12-2024
DANA MCNEAL A.K.A DANA BRANCH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE.
On May 24, 2024, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction and to Strike as to Taxable Year 2023 and Strike as to Notices of Deficiency for Taxable Years 2017, 2019, 2020, 2021, and 2022, on the grounds that (1) no notice of determination concerning collection action was sent to petitioner for tax year 2023, nor has respondent made any other determination as to tax year 2023 that would confer jurisdiction on this Court, and (2) no notice of deficiency was issued to petitioner for tax years 2017, 2019, 2020, 2021, or 2022. Respondent represents 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 relating to a notice of determination concerning collection action for tax year 2023, and so much of this case relating to a notice of deficiency, is dismissed for lack of jurisdiction and deemed stricken from the Court's record in this case.
Petitioner is advised that his case will continue with respect to the notice of determination concerning collection action that he was issued for tax years 2017, 2019, 2020, 2021, and 2022.