Opinion
7602-21
12-27-2021
Dion Sauve & Amber Sauve Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On July 6, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that petitioners paid the tax liability for tax year 2018 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency is invalid. Although the Court directed petitioners to file an objection, if any, to respondent's motion, petitioners failed to do so.
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.