Opinion
2148-21
01-24-2022
Victor Ramirez & Wendy K. E. Ramirez Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On May 7, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency has been issued to petitioners with respect to the taxable year 2017, nor has respondent made any other determination with respect to such year that would confer jurisdiction on this Court. Although the Court directed petitioners to file an objection, if any, to respondent's Motion to Dismiss, petitioners failed to do so. A review of the record reveals no indication that respondent has made any determination that would invoke this Court's jurisdiction over petitioners' 2017 taxable year.
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction.