Opinion
16062-21
07-08-2022
WILLIAM V. REDDEN & CHRISTINE R. MARINO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 10, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that no notice of final determination for full/partial disallowance of interest abatement claim has been issued to petitioners for tax year 2017 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.
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 final determination for full/partial disallowance of interest abatement claim for tax year 2017 is dismissed for lack of jurisdiction. Petitioners are reminded that so much of this case as relates to a notice of deficiency for tax year 2017 remains pending before the Court.