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Threadgill v. Comm'r of Internal Revenue

United States Tax Court
Dec 7, 2022
No. 37119-21S (U.S.T.C. Dec. 7, 2022)

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.


Summaries of

Threadgill v. Comm'r of Internal Revenue

United States Tax Court
Dec 7, 2022
No. 37119-21S (U.S.T.C. Dec. 7, 2022)
Case details for

Threadgill v. Comm'r of Internal Revenue

Case Details

Full title:TAMMY H. THREADGILL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Dec 7, 2022

Citations

No. 37119-21S (U.S.T.C. Dec. 7, 2022)