Opinion
9504-21
01-31-2022
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On November 10, 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 petitioner to file an objection, if any, to respondent's Motion to Dismiss, petitioner failed to do so. The record shows that the Petition was not timely filed.
Upon due consideration of the foregoing, it is
ORDERED that the Court's Order to Show Cause served August 9, 2021, is hereby made absolute. It is further
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction.