Opinion
12746-24S
11-04-2024
OMAR CASTILLO & MARIA CASTILLO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On August 19, 2024, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction on the grounds that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioners with respect to taxable year 2021, nor had respondent made any other determination with respect to that tax year that would confer jurisdiction on the Court. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners failed to do so.
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.