From Casetext: Smarter Legal Research

Cabral v. Comm'r of Internal Revenue

United States Tax Court
Dec 21, 2022
No. 12078-20S (U.S.T.C. Dec. 21, 2022)

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.


Summaries of

Cabral v. Comm'r of Internal Revenue

United States Tax Court
Dec 21, 2022
No. 12078-20S (U.S.T.C. Dec. 21, 2022)
Case details for

Cabral v. Comm'r of Internal Revenue

Case Details

Full title:CYNTHIA ANNE CABRAL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Dec 21, 2022

Citations

No. 12078-20S (U.S.T.C. Dec. 21, 2022)