Opinion
24222-22S
02-17-2023
EDMOND VALENCIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On December 21, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that petitioner paid the tax liability for tax year 2020 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency is invalid. Respondent states in the motion to dismiss that petitioner does not object to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted in that this case is dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.