Opinion
14385-20
06-25-2021
Spencer Clayton Anderson Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction filed on April 2, 2021, and supplemented on April 6, 2021. Respondent asserts in his motion, as supplemented, that no notice of deficiency or notice of determination was issued to petitioner for tax years 1995 through 2020 that would permit petitioner to invoke the jurisdiction of this Court with respect to those tax years. Petitioner's response, filed May 3, 2021, supports, rather than opposes respondent's motion. Taking into account representations contained in the petition, petitioner's response, and for the reasons set forth in respondent's motion, as supplemented, it is, ORDERED that respondent's above-described motion, as supplemented, is granted. It is further
ORDERED that with respect to each year placed in issue in the petition, this case is dismissed for lack of jurisdiction upon the ground stated in respondent's motion, as supplemented.