Opinion
12078-20S
12-21-2022
CYNTHIA ANNE CABRAL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Eunkyong Choi Special Trial Judge
On October 13, 2022, this Court filed an Order directing the parties to show cause, by November 11, 2022, why this case should not be dismissed for lack of jurisdiction on the grounds that the petition was not filed within the time prescribed by the Internal Revenue Code. Respondent filed a response on November 9, 2022, agreeing that this case should be dismissed for lack of jurisdiction. Petitioner has not filed a response. The record establishes that the petition was not timely filed. See I.R.C. sections 6015(e)(1)(A); and 7502; Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022); Rubel v. Commissioner, 856 F.3d 301 (3d Cir 2017).
Upon due consideration, it is
ORDERED that this case is dismissed for lack of jurisdiction.