Opinion
13602-22
06-06-2023
TODD SKLAR & KAREN SKLAR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On September 23, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to petitioner's Claim for Relief from Joint and Several Liability, seeking to dismiss this case on the ground that no notice of determination concerning relief from joint and several liability under section 6015 has been issued to petitioners for tax years 2008 through 2012, 2014, and 2015 that would confer jurisdiction on this Court. On February 21, 2023, respondent filed a supplement to his motion. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, as supplemented, petitioners failed to do so.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion, as supplemented, is granted in that so much of this case as relates to a notice of determination concerning relief from joint and several liability under section 6015 for tax years 2008 through 2012, 2014 and 2015 is dismissed for lack of jurisdiction. Petitioners are reminded that so much of this case as relates to a notice of determination concerning collection for tax years 2008 through 2012, 2014, and 2015 remains pending before the Court.
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