USCA11 Case: 24-13204 Document: 12-1 Date Filed: 01/31/2025 Page: 1 of 2

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-13204 Non-Argument Calendar ____________________ RICHARD HERBERT FRIEDBERG, Petitioner-Appellant, versus COMMISSIONER OF INTERNAL REVENUE,

Respondent-Appellee.

____________________ Petition for Review of a Decision of the U.S.Tax Court Agency No. 12456-20L ____________________ USCA11 Case: 24-13204 Document: 12-1 Date Filed: 01/31/2025 Page: 2 of 2

2 Opinion of the Court 24-13204

Before NEWSOM, BRANCH, and KIDD, Circuit Judges.

PER CURIAM: Richard Friedberg, proceeding pro se, petitions for review of the October 1, 2024, order of the U.S. Tax Court denying his mo- tion to strike the Commissioner of Internal Revenue’s (“the Com- missioner”) motion for summary judgment. A jurisdictional ques- tion (“JQ”) asked the parties whether the October 1 order is final or otherwise immediately reviewable. The Commissioner re- sponds that the October 1 order is not final or immediately review- able under the collateral order doctrine or any other authority.

Friedberg did not respond to the JQ.

We conclude that we lack jurisdiction over this appeal be- cause the October 1 order is not final or otherwise immediately re- viewable. See 26 U.S. § 7482(a)(1); 28 U.S.C. § 1291; CSX Transp., Inc. v. City of Garden City, 235 F.3d 1325, 1327 (11th Cir. 2000); Porter v. Comm’r of Internal Revenue, 453 F.2d 1231, 1232 (5th Cir. 1972).

Further, the October 1 order is not reviewable under the collateral order doctrine because it can be effectively reviewed after a final judgment is entered. See Plaintiff A v. Schair, 744 F.3d 1247, 1252-53 (11th Cir. 2014).

Accordingly, we DISMISS this appeal for lack of jurisdiction.

All pending motions are DENIED AS MOOT.