Barrett v. Comm'r of Internal Revenue

Full title: BILLY BARRETT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Feb 16, 2023

No. 4879-22S (U.S.T.C. Feb. 16, 2023)

Opinion

4879-22S

02-16-2023

BILLY BARRETT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Lewis R. Carluzzo Chief Special Trial Judge

ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Lewis R. Carluzzo Chief Special Trial Judge

This case for the redetermination of a deficiency is before the Court on respondent's motion to dismiss for lack of jurisdiction, filed January 18, 2023, and heard on February 13, 2023, when the case was called from the calendar in Houston, Texas. There was no appearance by or on behalf of petitioner. Counsel for respondent appeared and argued in support of the motion.

Premises considered, for the reasons set forth in respondent's motion, and for cause set forth more fully in the transcript of the above-referenced proceedings, it is

ORDERED that respondent's motion to dismiss is granted. It is further

ORDERED that this case is dismissed for lack of jurisdiction upon the ground that the petition was not filed within the time prescribed by I.R.C. § 6213(a).