Opinion
5545-21
10-18-2021
Edward F. Toole & Deborah J. Toole Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On July 16, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that petitioners paid the tax liability for tax year 2018 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency on which this case is based is invalid. Although the Court directed petitioners to file an objection, if any, to respondent's motion, to date petitioners have not done so.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction.