Opinion
6322-22
03-06-2023
FRANKIE BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER AND ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Alina I. Marshall Judge
On January 5, 2023, the parties filed a Proposed Stipulated Decision for the Court's Consideration. By Order to Show Cause, dated February 6, 2023, 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 February 13, 2023, respondent filed a Response to the order to show cause, stating that he does not know of any reason the Court should not dismiss this case for lack of jurisdiction. Respondent's response states that petitioner is not aware of any reason the Court should not dismiss this case for lack of jurisdiction. Upon due consideration, it is
ORDERED that the parties' P roposed Stipulated Decision, filed January 5, 2023, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that the Court's Order to Show Cause, dated February 6, 2023, 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 2018.