Opinion
28244-21
09-16-2022
PATRICIA CAMACHO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On December 13, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice has been issued to petitioner that would permit her to invoke the jurisdiction of this Court for the taxable years raised in the Petition, nor has respondent made any other determination for such years sufficient to confer jurisdiction on the Court. Although the Court directed petitioner to file an objection, if any, to the Motion to Dismiss, petitioner failed to do so.
Accordingly, and in view of petitioner's failure to carry her burden to "establish affirmatively all facts giving rise to our jurisdiction," David Dung Le, M.D., Inc. v. Commissioner, 114 T.C. 268, 270 (2000), aff 'd, 22 Fed.Appx. 837 (9th Cir. 2001), it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction.