Opinion
33547-21S
11-02-2023
PATRICK JONES OKELLO & CAROLINE OKELLO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Lewis R. Carluzzo Chief Special Trial Judge
This case for the redetermination of a deficiency is before the Court on respondent's motion to dismiss for lack of jurisdiction filed August 18, 2023. According to the motion, the Court is without jurisdiction in this case because the petition was not filed within the period prescribed by I.R.C. section 6213(a). Respondent's motion was heard in Dallas, Texas, on October 31, 2023. Counsel for respondent appeared and argued in support of the motion. There was no appearance by or on behalf of petitioner.
Premises considered, and for cause set forth more fully in the transcript of the above-referenced proceedings, it is
ORDERED that respondent's motion is granted, and this case is dismissed for lack of jurisdiction because the petition was not filed within the period prescribed by I.R.C. section 6213(a).