Opinion
6861-21
03-24-2022
Dean Sanchez Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge.
On June 25, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to Taxable Year 2020. On January 7, 2022, respondent filed a supplement to his motion. In the motion, as supplemented, respondent seeks to dismiss this case as to tax year 2020 on the ground that no notice of deficiency, no notice of determination concerning collection action, or any other notice of determination has been issued to petitioner for tax year 2020 that would confer jurisdiction on this Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner 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 deficiency for tax year 2020 is dismissed for lack of jurisdiction. Petitioner is reminded that so much of this case as relates to a notice of deficiency for tax year 2018 remains pending before the Court.
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