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Brady v. Comm'r of Internal Revenue

United States Tax Court
Mar 2, 2023
No. 6862-22 (U.S.T.C. Mar. 2, 2023)

Opinion

6862-22

03-02-2023

CRYSTAL MARIE BRADY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER AND ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

By Order To Show Cause, served December 23, 2022, the Court directed the parties to show cause why this case should not be dismissed for lack of jurisdiction on the ground that the petition was not timely filed. On January 11, 2023, respondent filed a Response to the order to show cause, asserting that the petition was untimely. Respondent attached to the Response a copy of the USPS tracking as evidence of the fact that the notice of deficiency was sent to petitioner by certified mail on July 19, 2021. The petition was electronically filed on April 1, 2022, which is 256 days after the mailing of the notice of deficiency. Petitioner failed to file a response to the Court's Order to Show Cause. The record establishes that the petition was not timely filed.

Upon due consideration, it is

ORDERED that the Court's Order to Show Cause, served December 23, 2022, is hereby made absolute. It is further

ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction on the ground that the petition was not timely filed as to tax year 2020.


Summaries of

Brady v. Comm'r of Internal Revenue

United States Tax Court
Mar 2, 2023
No. 6862-22 (U.S.T.C. Mar. 2, 2023)
Case details for

Brady v. Comm'r of Internal Revenue

Case Details

Full title:CRYSTAL MARIE BRADY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Mar 2, 2023

Citations

No. 6862-22 (U.S.T.C. Mar. 2, 2023)