Opinion
2125-23
05-24-2023
LEE VANG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On March 22, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2022 and To Strike on the grounds that petitioner has not been issued any notice of deficiency, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2022 tax year. Although the Court provided petitioner the opportunity to file an objection, if any, to respondent's motion, petitioner has not done so. Because petitioner has not produced any notice of deficiency or demonstrated that respondent made any other determination, that would permit petitioner to invoke the jurisdiction of this Court as to petitioner's 2022 tax year, the Court is obliged to dismiss for lack of jurisdiction so much of this case relating to tax year 2022.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2022 and To Strike is granted in that so much of this case relating to tax year 2022 is dismissed for lack of jurisdiction. Petitioner is advised that so much of this case relating to the notice of deficiency issued for petitioner's 2021 tax year remains pending before the Court.