Cook v. Comm'r of Internal Revenue

Full title: HELEN W. COOK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Aug 8, 2023

No. 7172-23 (U.S.T.C. Aug. 8, 2023)

Opinion

7172-23

08-08-2023

HELEN W. COOK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan, Chief Judge

ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan, Chief Judge

On May 26, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency and no notice of determination concerning collection action was issued to petitioner for tax years 1989 through 1991, nor has respondent made any other determination with respect to those years that would confer jurisdiction on this Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so.

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.