Opinion
794-21S
02-16-2022
John R Bower Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
RICHARD T. MORRISON JUDGE
On February 1, 2022, respondent moved that this case be dismissed for lack of jurisdiction insofar as it relates to the 2018 and 2019 tax years upon the ground that no statutory notice of deficiency, as authorized by I.R.C. section 6212 and required by I.R.C. section 6213(a) to form the basis for a petition to this Court has been sent to petitioner with respect to taxable year 2018 or 2019, nor has respondent made any other determination with respect to petitioner's taxable year 2018 or 2019 that would confer jurisdiction on this Court.
The Court ordered petitioner to file a response to respondent's aforementioned motion by February 11, 2022. As of the date of this Order and Order of Dismissal for Lack of Jurisdiction, no response has been received by or on behalf of petitioner.
It is
ORDERED that respondent's February 1, 2022 motion to dismiss for lack of jurisdiction insofar as it relates to the 2018 and 2019 tax years is granted and the 2018 and 2019 tax years are dismissed for lack of jurisdiction and all portions of the petition in which reference is made to the taxable years 2018 and 2019 are stricken.