Opinion
22503-21
10-13-2021
Barbara S. Blair Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On June 21, 2021, the Court received from petitioner correspondence, attached to which was a copy of a notice of deficiency dated March 22, 2021, issued to petitioner with respect to the 2018 taxable year. To protect petitioner's statutory time period within which to begin a case, the Court filed those materials, although not properly signed, as a petition to commence this case at Docket No. 22503-21. On September 20, 2021, the Court issued an Order directing the filing of a Ratification of Petition for this litigation on or before November 1, 2021. On October 4, 2021, the Court then received from petitioner a further letter indicating that petitioner petitioner preferred to work administratively through the Internal Revenue Service to resolve the 2018 tax matters, and had done so, rather than to continue with the instant Court proceeding. An earlier letter to the same effect, received July 12, 2021, had due to inadvertent clerical error been filed as a purported Motion for Entry of Decision, resulting in delay.
Accordingly, it appearing that petitioner does not intend to file a Ratification of Petition as directed in the Court's Order dated October 4, 2021, it is
ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction. It is further
ORDERED that the purported Motion for Entry of Decision filed July 12, 2021, is denied.
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