Opinion
32329-21S
12-07-2022
ROBERT P. BRYCE & ERIN C. BRYCE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Eunkyong Choi Special Trial Judge.
On November 3, 2022, the parties filed a Proposed Stipulated Decision (index #9) for the Court's consideration. That same day, respondent filed a Motion to Dismiss for Lack of Jurisdiction (index #10) on the grounds that the petition was not filed within the time prescribed by the Internal Revenue Code. The record establishes that the petition was not timely filed. See I.R.C. sections 6213(a) and 7502; Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022).
Upon due consideration, it is hereby
ORDERED that the parties' Proposed Stipulated Decision, filed November 3, 2022, (index #10) is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction filed November 3, 2022, (index #9) is granted and this case is dismissed for lack of jurisdiction.