Opinion
12402-20SL
01-05-2022
Brian Keith Mullen Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
MAURICE B. FOLEY CHIEF JUDGE
On January 25, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction and to Strike on the ground that no notice of deficiency, no notice of final determination for disallowance of interest abatement claim, no notice of worker classification, and no notice of determination concerning collection action has been issued to petitioners for tax years 2018 and 2019 that would confer jurisdiction on this Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so.
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, notice of final determination for full / partial disallowance of interest abatement claim, notice of worker classification, and notice of determination concerning collection action 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 determination concerning collection action for tax year 2016 remains pending before the Court.
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