Opinion
11963-22
10-06-2022
GEOFFREY W. PENMAN & SAMANTHA CASE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On July 19, 2022, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Years 2019 and 2020 and To Strike, on the ground that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioners with respect to taxable years 2019 and 2020, nor had respondent made any other determination with respect to petitioners' tax years 2019 and 2020 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction as to the Taxable Years 2019 and 2020 and To Strike is granted, and this case is dismissed for lack of jurisdiction as to taxable years 2019 and 2020. References to those years in the petition are deemed stricken.