Opinion
24169-22S
01-04-2024
WILLA BURTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Emin Toro, Judge.
On December 20, 2023, respondent filed a Status Report (Doc. 9) informing the Court that "[r]espondent intends to file a Motion to Dismiss for Lack of Jurisdiction in this case and is in the process of retrieving the Certified Mail Listing. Despite the late filing of the [P]etition, respondent and petitioner reached a settlement determining that there is no deficiency in income tax due from, nor overpayment due to, petitioner for the taxable year 2020."
On January 3, 2024, respondent filed an unopposed Motion to Dismiss for Lack of Jurisdiction (Doc. 10) on the ground that the Petition was not filed within the time prescribed by I.R.C. § 6213(a) or 7502.
Upon due consideration, it is hereby
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction filed January 3, 2024, is granted, and this case is dismissed for lack of jurisdiction.