Opinion
17747-21S
01-04-2022
Michael Karl Mollet Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
EUNKYONG CHOI SPECIAL TRIAL JUDGE
December 29, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Collection Action and Notice of Final Determination for Full / Partial Disallowance of Interest Abatement Claim on the grounds that no notice of determination concerning collection action or notice of final determination for full/partial disallowance of interest abatement claim has been issued to petitioner for tax years 2018 and 2019 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 years 2018 and 2019 and so much of this case as relates to a notice of final determination for full/partial disallowance of interest abatement claim for tax years 2018 and 2019 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.
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