Opinion
17329-23
08-27-2024
BRIAN CHRISTOPHER BANNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
David Gustafson Judge.
In November 2023 petitioner Brian Christopher Banner filed a petition in this Court, purporting to challenge pursuant to I.R.C. section 6213(a) a notice of deficiency that he asserted the Internal Revenue Service had issued to him, pursuant to section 6212(a), for the year 2020. He attached several pieces of IRS correspondence to his petition, but none of them is a notice of deficiency. On August 26, 2024, the Commissioner filed a motion (Doc. 12) to dismiss the case for lack of jurisdiction, showing that no notice of deficiency has been issued to Mr. Banner for 2020 that could confer on this Court jurisdiction over this case. The motion indicates that Mr. Banner does not dispute that showing and does not object to the dismissal of his case. It is therefore
ORDERED that the motion (Doc. 12) is granted and that this case is dismissed for lack of jurisdiction.