Opinion
12905-21L
12-13-2021
Alana K. Barksdale & Keith Barksdale Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
MAURICE B. FOLEY, CHIEF JUDGE
On August 27, 2021, respondent filed a motion to dismiss for lack of jurisdiction on the ground that with respect to the notices of determination concerning collection action on which this case is based the petition was not filed within the time prescribed by the Internal Revenue Code. Although the Court directed petitioners to file an objection, if any, to respondent motion, the Court has received no response from petitioners.
Upon due consideration, it is
ORDERED that respondent's motion to dismiss for lack of jurisdiction is granted and this case is dismissed for lack of jurisdiction.