Opinion
24287-22S
03-02-2023
DOROTHY L. WERE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On January 11, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to the Notice of Determination Concerning Collection Action and the Taxable Year 2018 and to Strike on the grounds that the petition was not filed within the time prescribed by the Internal Revenue Code for the notice of deficiency issued to petitioner as to tax year 2018 and that no notice of determination concerning collection action has been issued to petitioner for tax years 2018, 2019, and 2020 that would confer jurisdiction on this Court. Respondent states in the motion 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 as to the Notice of Determination Concerning Collection Action and the Taxable Year 2018 and To Strike is granted in that so much of this case as relates to a notice of deficiency for tax year 2018 and a notice of determination concerning collection action for tax years 2018, 2019, and 2020 is dismissed for lack of jurisdiction. Petitioner is reminded that so much of this case as relates to a notice of deficiency for tax years 2019 and 2020 remains pending before the Court.