Opinion
2815-22
07-20-2022
ALAN ALBERT PADILLA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 25, 2022, respondent filed a motion to dismiss for lack of jurisdiction as to and to strike as to taxable years 2020 and 2021 on the ground that no notice of deficiency or notice of determination for tax years 2020 and 2021 sufficient to confer jurisdiction on this Court was issued to petitioner. Respondent states that petitioner has no objection to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is granted and so much of this case relating to petitioner's 2020 and 2021 tax years is dismissed for lack of jurisdiction and is deemed stricken from the Court's record. Petitioner is advised that so much of this case relating to a notice of deficiency issued for his 2019 tax year remains pending before the Court.