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Schaffer v. Comm'r of Internal Revenue

United States Tax Court
Nov 7, 2022
No. 18971-21S (U.S.T.C. Nov. 7, 2022)

Opinion

18971-21S

11-07-2022

DARIN PAUL SCHAFFER & LESLIE RAY SCHAFFER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan, Chief Judge.

On October 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 and this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.


Summaries of

Schaffer v. Comm'r of Internal Revenue

United States Tax Court
Nov 7, 2022
No. 18971-21S (U.S.T.C. Nov. 7, 2022)
Case details for

Schaffer v. Comm'r of Internal Revenue

Case Details

Full title:DARIN PAUL SCHAFFER & LESLIE RAY SCHAFFER, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Nov 7, 2022

Citations

No. 18971-21S (U.S.T.C. Nov. 7, 2022)