Opinion
1615-23S
04-14-2023
JUNHO SONG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 12, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to 2018 on the grounds that no notice of deficiency was issued to petitioner, nor has respondent made any other determination, concerning petitioner's 2018 tax year that would permit petitioner to invoke the jurisdiction of this Court. Respondent represents that petitioner has no objection to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to 2018 is granted and so much of this case relating to tax year 2018 is dismissed for lack of jurisdiction and deemed stricken from the Court's record. Petitioner is advised that petitioner's claims relating to the notice of deficiency issued for petitioner's 2021 tax year remain pending before the Court.