Opinion
37119-21S
12-07-2022
TAMMY H. THREADGILL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On March 11, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the petition was not filed within the time prescribed in the Internal Revenue Code. Although the Court provided petitioner the opportunity to file an objection, if any, to respondent's motion, petitioner has not done so. The record establishes that the petition was filed after the applicable 90-day filing period had expired. See I.R.C. sections 6213(a) and 7502; Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022).
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction.