Opinion
14064-23
01-19-2024
JENNIFER R. NIMMO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
By Order to Show Cause served November 6, 2023, the Court directed each party to file a response showing cause in writing why so much of this case relating to a notice of final determination for disallowance of interest abatement claim for the taxable years 2016 and 2017 should not be dismissed for lack of jurisdiction.
On November 28, 2023, respondent filed a Response. Therein, respondent states that this case should be dismissed for lack of jurisdiction as to such a notice. To date, petitioner has failed to respond to the Court's Order to Show Cause.
Upon due consideration and for cause, it is ORDERED that the Court's Order to Show Cause is hereby made absolute. It is further
ORDERED that so much of this case relating to a notice of final determination for disallowance of interest abatement claim for the taxable years 2016 and 2017 is dismissed for lack of jurisdiction. All references to such a notice are deemed stricken from the Petition.
Petitioner is informed that so much of this case relating to the notice of determination concerning relief from joint and several liability under I.R.C. section 6015 issued to her for the taxable years 2016 and 2017 remains pending before the Court.