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Kirkland v. Comm'r of Internal Revenue

United States Tax Court
Oct 31, 2022
No. 15833-22L (U.S.T.C. Oct. 31, 2022)

Opinion

15833-22L

10-31-2022

MARDI KIRKLAND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan, Chief Judge

On August 26, 2022, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction and To Strike as to Taxable Years 2014 and 2015, 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, or notice of determination concerning collection action pursuant to section 6320 and/or 6330, I.R.C., had been sent to petitioner with respect to taxable years 2014 and 2015, nor had respondent made any other determination with respect to petitioner's tax years 2014 and 2015 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, it is

ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction and To Strike as to Taxable Years 2014 and 2015 is granted, and this case is dismissed for lack of jurisdiction as to taxable years 2014 and 2015. References to those years in the petition are deemed stricken.


Summaries of

Kirkland v. Comm'r of Internal Revenue

United States Tax Court
Oct 31, 2022
No. 15833-22L (U.S.T.C. Oct. 31, 2022)
Case details for

Kirkland v. Comm'r of Internal Revenue

Case Details

Full title:MARDI KIRKLAND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court:United States Tax Court

Date published: Oct 31, 2022

Citations

No. 15833-22L (U.S.T.C. Oct. 31, 2022)