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Brown v. Comm'r of Internal Revenue

United States Tax Court
Mar 15, 2023
No. 7422-22 (U.S.T.C. Mar. 15, 2023)

Opinion

7422-22

03-15-2023

MARLENE BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On May 25, 2022, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioner with respect to taxable year 2018, 2019, 2020, and/or 2021, nor had respondent made any other determination with respect to petitioner's tax years 2018, 2019, 2020, and/or 2021 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner has failed to do so.

Upon due consideration, it is

ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction is granted, and this case is dismissed for lack of jurisdiction. It is further

ORDERED that petitioner's Motion To Proceed Remotely, filed May 2, 2022, is denied as moot.


Summaries of

Brown v. Comm'r of Internal Revenue

United States Tax Court
Mar 15, 2023
No. 7422-22 (U.S.T.C. Mar. 15, 2023)
Case details for

Brown v. Comm'r of Internal Revenue

Case Details

Full title:MARLENE BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court:United States Tax Court

Date published: Mar 15, 2023

Citations

No. 7422-22 (U.S.T.C. Mar. 15, 2023)