Opinion
14385-21S
12-09-2021
John A. Miller, Sr Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley, Chief Judge.
On September 1, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. Although the Court directed petitioner to file an objection, if any, to respondent's motion, to date no response has been received from petitioner. The record establishes that the petition was not timely filed and, thus, this Court has no jurisdiction of this matter. However, although petitioner may not prosecute this case in this Court, petitioner may still seek to administratively resolve his 2018 tax liability directly with the IRS.
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.