Opinion
24228-21
03-11-2022
Gary H. Noble & Lisa H. Noble Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On July 6, 2021, the Court received from petitioners a letter, attached to which was a copy of a notice of deficiency dated April 5, 2021, issued to petitioners with respect to the 2018 taxable year. To protect petitioners' statutory time period within which to begin a case, the Court filed that letter as a petition to commence this case at Docket No. 24228-21. On November 5 and November 13, 2021, the Court issued Orders directing the filing of a Ratification of Petition and payment of the filing fee for this litigation on or before November 15 and November 23, 2021, respectively. On November 15, 2021, the Court then received from petitioners a further letter indicating that petitioners did not intend by the initial correspondence with this Court to begin a case herein and that petitioners preferred to work administratively through the Internal Revenue Service to resolve the 2018 tax matters, and had apparently done so, rather than to continue with the instant Court proceeding. Accordingly, it appearing that petitioners do not intend to file a Ratification of Petition and pay the filing fee as directed in the Court's Orders, it is
ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction.