Opinion
36694-21
11-23-2022
DWAYNE L. WILLIAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
KATHLEEN KERRIGAN CHIEF JUDGE
On March 16, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency, nor any other determination that would permit petitioner to invoke the jurisdiction of this Court in this case, has been issued to petitioner. Although the Court directed petitioner to file an objection, if any, to the Motion to Dismiss, petitioner failed to do so. There is no indication in the record that petitioner has been issued any notice or other determination that would be sufficient to confer jurisdiction on the Court in this case.
Accordingly, and in view of petitioner's failure to "establish affirmatively all facts giving rise to our jurisdiction," David Dung Le, M.D., Inc. v. Commissioner, 114 T.C. 268, 270 (2000), aff 'd, 22 Fed.Appx. 837 (9th Cir. 2001), it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction.