Opinion
26269-21
03-03-2022
Albert Francis & Shelia D. Francis Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge.
On October 28, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. Although the Court directed petitioners to file an objection, if any, to respondent's motion, to date no response has been received from petitioners. The record establishes that the petition was not timely filed.
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.