Opinion
27696-21
12-15-2021
Eric Zachary Silfen Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
MAURICE B. FOLEY CHIEF JUDGE
On December 9, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to a Notice of Deficiency for Tax Years 2017 and 2019 and Notice of Final Determination for Interest Abatement Claim (or Failure of IRS to Make Final Determination Within 180 Days After Claim for Abatement) for Tax Years 2017, 2018, and 2019 and To Strike. In his motion respondent states that petitioner does not object to the granting of the motion. Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted in that so much of this case relating to (1) a notice of deficiency for 2017 and 2019 or (2) a notice of final determination for interest abatement claim (or failure of IRS to make final determination) for 2017, 2018, and 2019, is dismissed for lack of jurisdiction. It is further
ORDERED that all references in paragraph 1 of the petition to a notice of deficiency for 2017 and 2019 and to interest abatement for 2017, 2018, and 2019, are deemed stricken.