Opinion
9472-23
10-16-2023
JAMES C. RAVINDRAN & SAVITHRI P. RAVINDRAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On August 9, 2023, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that no valid notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code to form the basis for a petition to this Court, had been issued to petitioners with respect to taxable years 2015 and 2016. In the motion to dismiss, respondent explained that the purported notice did not determine a deficiency or overpayment that would confer jurisdiction upon the Court as required by section 6214(a) and 6512(b), I.R.C. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so.
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 purported notice of deficiency is invalid.