Opinion
16147-21S
09-17-2021
Peter D. Johnston & Mary A. Johnston Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On September 8, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground the petition was not filed within the time prescribed in the Internal Revenue Code. Respondent states in the motion to dismiss that petitioners do not object to the granting of the motion. The record shows 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.
1