Opinion
13022-22S
02-15-2023
GLENN LEE ROBERTS & CARMEN C. ROBERTS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On December 9, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that petitioners paid the tax liability for tax year 2019 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency is invalid. On February 12, 2023, petitioners filed a Notice of No Objection to Motion to Dismiss for Lack of Jurisdiction.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted in that this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.