Opinion
7964-23
04-18-2024
JEFFREY S. CAREFOOT & MICHELLE R. CAREFOOT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
James S. Halpern, Judge.
By Notice served December 27, 2023, this case was calendared for trial on the Court's San Diego, California trial calendar which commenced on April 15, 2024. On March 8, 2024, respondent filed a motion with the Court to dismiss this case for lack of jurisdiction on the ground that the petition was not filed within the time period prescribed by I.R.C. sections 6213(a) or 7502.
On April 15, 2024, this case was called from the calendar at the Trial Session of the Court in San Diego, California. Both petitioner and counsel for respondent appeared and were heard on the motion.
Upon due consideration and for cause more fully appearing in the transcript of the proceedings, it is
ORDERED that respondent's motion to dismiss for lack of jurisdiction filed on March 8, 2024, is granted and this case is dismissed for lack of jurisdiction.