Opinion
37955-21
04-19-2024
KEITH M. PHILLIPS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Travis A. Greaves, Judge.
Pursuant to the determination of this Court, as set forth in its Memorandum Opinion (T.C. Memo. 2024-44), filed April 16, 2024, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed September 2, 2021, and supplemented on November 19, 2021, and June 23, 2023, is denied. It is further
ORDERED that, sua sponte, this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.