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Fabozzi v. Comm'r of Internal Revenue

United States Tax Court
Jan 27, 2023
No. 21547-21 (U.S.T.C. Jan. 27, 2023)

Opinion

21547-21

01-27-2023

JENNIFER ELIZABETH FABOZZI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On November 1, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the ground that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioner with respect to taxable years 1998 through 2019, nor had respondent made any other determination with respect to petitioner's tax years 1998 through 2019, including any determination pursuant to section 6320 and/or 6330, I.R.C., that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner has failed to do so.

Upon due consideration, taking into account representations contained in the petition, and for the reasons set forth in respondent's motion, it is, ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted, and this case is dismissed for lack of jurisdiction with respect to each year placed in issue in the petition upon the ground stated in respondent's motion.


Summaries of

Fabozzi v. Comm'r of Internal Revenue

United States Tax Court
Jan 27, 2023
No. 21547-21 (U.S.T.C. Jan. 27, 2023)
Case details for

Fabozzi v. Comm'r of Internal Revenue

Case Details

Full title:JENNIFER ELIZABETH FABOZZI, Petitioner v. COMMISSIONER OF INTERNAL…

Court:United States Tax Court

Date published: Jan 27, 2023

Citations

No. 21547-21 (U.S.T.C. Jan. 27, 2023)