Opinion
23252-22S
03-07-2023
JOHN R. ROTTIER & MARILYN I. ROTTIER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On February 7, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that petitioners paid the tax liability for tax year 2020 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency is invalid. Respondent states in the motion to dismiss that petitioners do not object to the granting of the motion.
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.