Kessler v. Comm'r of Internal Revenue

Full title: Paul Kessler Petitioner v. Commissioner of Internal Revenue Respondent

Court: United States Tax Court

Date published: Mar 25, 2022

No. 27060-21 (U.S.T.C. Mar. 25, 2022)

Opinion

27060-21

03-25-2022

Paul Kessler Petitioner v. Commissioner of Internal Revenue Respondent

Maurice B. Foley, Chief Judge

ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Maurice B. Foley, Chief Judge

On December 13, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds 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 year 2020, nor had respondent made any other determination with respect to petitioner's tax year 2020 that would confer jurisdiction on the Court, as of the date the petition herein was filed.

Subsequently, on December 18, 2021, petitioner filed a response to respondent's motion, consenting to the dismissal on the stated grounds.

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.