Opinion
12262-20
01-06-2022
Richard Joseph Valle Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On February 22, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that no notice of determination concerning collection action has been issued to petitioner for tax year 2017 that would confer jurisdiction on this Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is granted in that so much of this case as relates to a notice of determination concerning collection for tax year 2017 is dismissed for lack of jurisdiction. Petitioner is reminded that so much of this case as relates to a notice of deficiency for tax year 2017 remains pending before the Court.