Opinion
21104-18P
06-23-2021
URIAH I. SHITRIT, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER AND ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Patrick J. Urda, Judge
Pursuant to the determination of the Court as set forth in its Memorandum Opinion (T.C. Memo. 2021-63), filed May 20, 2021, it is
ORDERED that respondent's motion to dismiss for lack of jurisdiction as to petitioner's claim upon the ground that I.R.C. section 7345 does not provide jurisdiction for petitioner's claims under I.R.C. Section 7803(a)(3) with respect to petitioner's 2006 tax year or his claim for the refund of an overpayment with respect to petitioner's tax year 2016, filed December 12, 2019, is granted. It is further
ORDERED that respondent's motion to dismiss on grounds of mootness, filed December 12, 2019, is granted, and this case is dismissed.