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Petchatat v. Comm'r of Internal Revenue

United States Tax Court
Mar 1, 2023
No. 22467-21S (U.S.T.C. Mar. 1, 2023)

Opinion

22467-21S

03-01-2023

NANTAWOOT PETCHATAT & JILL NGUYEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan, Chief Judge

On March 7, 2022, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction and To Strike as to 2019, 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 year 2019, nor had respondent made any other determination with respect to petitioners' tax year 2019 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioners 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 and To Strike as to 2019 is granted, and this case is dismissed for lack of jurisdiction as to taxable year 2019. References to that year in the petition are deemed stricken.


Summaries of

Petchatat v. Comm'r of Internal Revenue

United States Tax Court
Mar 1, 2023
No. 22467-21S (U.S.T.C. Mar. 1, 2023)
Case details for

Petchatat v. Comm'r of Internal Revenue

Case Details

Full title:NANTAWOOT PETCHATAT & JILL NGUYEN, Petitioners v. COMMISSIONER OF INTERNAL…

Court:United States Tax Court

Date published: Mar 1, 2023

Citations

No. 22467-21S (U.S.T.C. Mar. 1, 2023)