Opinion
12955-20
03-22-2022
Richard Brownstein a.k.a. Richard A. Brownstein Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL
Patrick J. Urda, Judge
This case is currently calendared on the Court's New York, New York, trial session, scheduled to begin April 25, 2022.
On March 15, 2022, the Commissioner filed a motion to dismiss for lack of jurisdiction on two grounds. The Commissioner first asserted that there was no statutory notice of deficiency as authorized by I.R.C. § 6212 and as required by I.R.C. § 6213(a) to form a basis for a petition in this Court has been sent to petitioner, Richard Brownstein a.k.a. Richard A. Brownstein, nor has the Commissioner made any other determination with respect to Mr. Brownstein's taxable years 2000, 2002, 2003, 2004, 2009, 2010, 2012, 2013, 2015, 2016, 2017, 2018 and 2019, that would confer jurisdiction on this Court. The Commissioner second stated that the petition was not filed within the time as prescribed by I.R.C. § 6213(a) or § 7502, and that the Commissioner has made no other determination sufficient to confer jurisdiction on this Court with respect to taxable years 2001, 2005, 2006, 2007, 2008, 2011, and 2014. The motion indicated that Mr. Brownstein does not oppose to the granting of this motion.
Upon due consideration, it is
ORDERED that the Commissioner's motion to dismiss for lack of jurisdiction is granted, and this case is dismissed.