Opinion
17687-22
02-16-2023
TERESA M. MERTZ & ROGER W. MERTZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 14, 2022, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to No Notice of Deficiency for Taxable Year and as to No Notices of Determination Concerning Collection Action for Taxable Years 2020 and 2021 on the ground that no notice of deficiency has been issued to petitioners for tax year 2021 and no notice of final determination concerning collection action has been issued to petitioners for tax years 2020 through 2021 that would confer jurisdiction on this Court. In the motion, respondent states that petitioners do 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 deficiency for tax year 2021 and a notice of determination concerning collection action for tax years 2020 and 2021 is dismissed for lack of jurisdiction. Petitioners are reminded that so much of this case as relates to a notice of deficiency for tax year 2020 remains pending before the Court.