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Tiffner v. Comm'r of Internal Revenue

United States Tax Court
Jan 10, 2023
No. 34234-21S (U.S.T.C. Jan. 10, 2023)

Opinion

34234-21S

01-10-2023

COLEEN ANN TIFFNER & ROBERT SHERMAN TIFFNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On February 3, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the Petition in this case 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 Dismiss, petitioners failed to do so. The record shows that the Petition was not timely filed. See I.R.C. §§ 6213(a), 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 above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction.


Summaries of

Tiffner v. Comm'r of Internal Revenue

United States Tax Court
Jan 10, 2023
No. 34234-21S (U.S.T.C. Jan. 10, 2023)
Case details for

Tiffner v. Comm'r of Internal Revenue

Case Details

Full title:COLEEN ANN TIFFNER & ROBERT SHERMAN TIFFNER, Petitioners v. COMMISSIONER…

Court:United States Tax Court

Date published: Jan 10, 2023

Citations

No. 34234-21S (U.S.T.C. Jan. 10, 2023)