Opinion
2461-21
12-23-2021
Kendra Carter Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley, Chief Judge.
On May 12, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the grounds that the petition was not timely filed with respect to the notice of deficiency issued to petitioner for tax year 2017 and no notice of deficiency was issued to petitioner for tax years 2018 through 2020 prior to petitioner filing the petition. In the motion, respondent states that a notice of deficiency for petitioner's tax year 2018 was issued to her on January 22, 2021. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so. The record shows that the petition was not timely filed with respect to the notice of deficiency issued to petitioner for tax year 2017 and there is no indication that respondent issued a notice of deficiency to petitioner for tax years 2019 and 2020.
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.