Opinion
18579-22
10-04-2022
TONY L. RUMPEL, DECEASED & BARBARA L. RUMPEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion to Dismiss for Lack of Jurisdiction, filed October 3, 2022, 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 on which this case is based is invalid, and there being no objection to the granting of that motion, 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 notice of deficiency on which this case is based is invalid.