Opinion
2526-22
04-12-2022
ANDREW S. KATZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction, filed April 7, 2022, on the grounds that: (1) no notice of deficiency or other notice of determination was issued to petitioner for taxable years 2012 through 2014, and 2016 through 2021 that would confer jurisdiction upon the Court; and (2) the petition was not filed timely as to the deficiency notice issued to petitioner for taxable year 2015, nor was any other notice of determination issued to petitioner for taxable year 2015 that would confer jurisdiction upon the Court. In his motion to dismiss respondent states that petitioner does not object to the granting of the motion. 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 is granted. It is further
ORDERED that with respect to each year placed in issue in the petition, this case is dismissed for lack of jurisdiction upon the ground stated in respondent's motion.