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.