Opinion
3437-22S
03-10-2023
RYAN J. STEGBAUER & JESSICA N. STEGBAUER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 18, 2022, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction as to the taxable year 2021 and to strike, on the ground that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioners with respect to taxable year 2021, nor had respondent made any other determination with respect to petitioners' tax year 2021 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so. [
Upon due consideration, it is
ORDERED that respondent's just-referenced motion is granted in that this case is dismissed for lack of jurisdiction as to taxable year 2021. References to that year in the petition are deemed stricken.