Opinion
10287-21
01-04-2022
Annamalai Annamalai Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
LEWIS R. CARLUZZO CHIEF SPECIAL TRIAL JUDGE
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction, filed July 27, 2021. According to the motion, respondent has not issued a notice of deficiency or made any other determination that could support the Court's jurisdiction in this case. Petitioner's objection to respondent's motion was filed August 11, 2021, Nothing submitted by petitioner or otherwise included in the record in this case shows that respondent has acted, or failed to act in any manner that could support this Court's jurisdiction in this matter. That being so, for the reasons set for the in respondent's motion to dismiss for lack of jurisdiction, it is
ORDERED that respondent's motion is granted. It is further
ORDERED that his case is dismissed for lack of jurisdiction upon the ground that there has been no showing that respondent has issued a notice of deficiency or any other notice of determination, or that respondent has failed to act in any manner that could support the Court's jurisdiction over the year or years referenced in the petition. Because the Court has no jurisdiction in this case, it is further
ORDERED that petitioner's motion for summary judgment, and petitioner's motion to compel production of documents, both filed July 30, 2021, are moot.