Opinion
9443-22
02-22-2023
MICHAEL D. SIEGEL & REGINA A. SIEGEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
JUAN F. VASQUEZ, JUDGE.
On January 26, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to taxable year 2018 on the ground that petitioners did not file a timely petition for the 2018 tax year. Respondent states in the motion that petitioners do not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is granted in that so much of this case as relates to the taxable year 2018 is dismissed for lack of jurisdiction. Petitioners are reminded that so much of this case as relates to a notice of deficiency for tax year 2019 remains pending before the Court.