Opinion
17141-22
12-29-2023
ROGER ROSBOUGH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Cary Douglas Pugh, Judge
This case is currently set for trial at the Court's January 29, 2024, Miami, Florida trial session. On December 21, 2023, respondent filed an unopposed Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not filed within the time prescribed by I.R.C. § 6015(e) or § 7502, and represented that petitioner did not object. Upon due consideration and for cause, it is hereby
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed December 21, 2023, is granted and this case is dismissed for lack of jurisdiction on the ground that the petition was not filed within the time prescribed by I.R.C § 6015(e) or § 7502.