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.