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.