Opinion
11634-20S
04-19-2022
William Frederick Melvin & Alta Maree Melvin Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge.
On November 20, 2020, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that petitioners paid the tax liability for tax year 2017 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency is invalid. Respondent states in the motion that petitioners do not object to the granting of respondent's motion.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted in that this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.