Opinion
19245-21
01-14-2022
Manuel Serru & Zasha Leal Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On October 7, 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 petitioners to file an objection, if any, to respondent's motion, to date no response has been received from petitioners. The record establishes that the petition was not timely filed.
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.