Opinion
13797-21
11-04-2021
Jere Rivera-Dugenio Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction, filed October 21, 2021. The motion seeks to dismiss this case on the grounds that: (1) no notice of deficiency was issued to petitioner for tax years 1999 through 2019; (2) no notice of determination concerning collection action was issued to petitioner for tax years 1999 through 2019; and (3) respondent has not made any other determination with respect to tax years 1999 through 2019 that would confer jurisdiction on the Court. Taking into account representations contained in the petition and for the reasons set forth in respondent's motion, it is, ORDERED that respondent's motion is granted. It is further
ORDERED that with respect to each year placed in issue in the petition, this case is dismissed for lack of jurisdiction upon the ground stated in respondent's motion.