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Pettinato v. Comm'r of Internal Revenue

United States Tax Court
Aug 3, 2022
No. 12107-20L (U.S.T.C. Aug. 3, 2022)

Opinion

12107-20L

08-03-2022

TERRY ROCHELLE PETTINATO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge

On January 12, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to the 2016 taxable year insofar as it Related to the Decision Letter for Taxable Year 2016 on the ground that no notice determination concerning collection action was issued with respect to the Notice of Federal Tax Lien for 2016. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so.

Upon due consideration, it is

ORDERED that respondent's above-referenced motion is granted in that so much of this case as relates to a notice of determination concerning collection action for the Notice of Federal Tax Lien for tax year 2016 is dismissed for lack of jurisdiction. Petitioner is reminded that so much of this case as relates to a notice of determination concerning collection action for the proposed levy for tax year 2016 remains pending before the Court.


Summaries of

Pettinato v. Comm'r of Internal Revenue

United States Tax Court
Aug 3, 2022
No. 12107-20L (U.S.T.C. Aug. 3, 2022)
Case details for

Pettinato v. Comm'r of Internal Revenue

Case Details

Full title:TERRY ROCHELLE PETTINATO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Aug 3, 2022

Citations

No. 12107-20L (U.S.T.C. Aug. 3, 2022)