Opinion
19796-21
03-23-2023
HUGH N. WRIGLEY & DIANA J. CRAWFORD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's October 24, 2022 trial calendar for Atlanta, Georgia. We continued it at the parties' request because petitioners' counsel spotted a TEFRA procedural tangle that respondent wanted to analyze. Both parties now agree that the 2016 and 2017 tax years need to be dismissed for lack of jurisdiction for making partnership determinations in a notice of deficiency sent to individual partners. It is therefore
ORDERED that the parties' February 17, 2023 motion to dismiss is granted, and this case is dismissed for lack of jurisdiction as to tax years 2016 and 2017.