Opinion
22155-21
03-08-2022
John C. Poland & Gwendolyn B. Poland Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On October 29, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that petitioners paid the tax liability for tax year 2018 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency on which this case is based is invalid. Although the Court provided petitioners an opportunity to file an objection, if any, to respondent's motion, no response has been received from petitioners.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid.