Opinion
9892-23
01-22-2024
SATI OZBERK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On June 21, 2023, petitioner filed the petition, seeking review of a notice of determination concerning collection action and a notice of final determination for disallowance of interest abatement for tax year 2018. On August 11, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction, seeking to dismiss this case because it was untimely as to a notice of deficiency issued for tax year 2018.
On January 19, 2024, respondent filed a status report, in which respondent states that he issued petitioner a Final Determination Letter on June 6, 2023, as to petitioner's request for relief from joint and several liability for petitioner's 2018 tax year and that petitioner's petition as to that notice is timely. In the status report, respondent requests that his Motion to Dismiss for Lack of Jurisdiction be denied.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed August 11, 2023, is denied.