Opinion
11708-20
10-06-2021
Jack Aaron Skinner & Chelsea Corrine Skinner Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge.
On November 12, 2020, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the grounds that: (1) No notice of Final determination for full or partial disallowance of an interest abatement claim pursuant to section 6404(h) of the Internal Revenue Code (I.R.C.), had been sent to petitioners for the tax year 2011, 2012, 2013, 2014, 2015, and 2016; and (2) respondent had not made any other determination with respect to petitioners' such tax years that would confer jurisdiction on the Court. A first supplement followed on December 28, 2020, and a second supplement on February 3, 2021, the latter of which advised that no proper interest abatement claim within the parameters of section 6404(h)(1)(A)(ii), I.R.C., has been submitted to the Internal Revenue Service (IRS). Although the Court directed petitioners to file an objection, if any, to respondent's motion, as supplemented, petitioners have failed to do so.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction, as supplemented, is granted, and this case is dismissed for lack of jurisdiction.
1