Opinion
6930-22
07-20-2022
MALGOSIA CEGIELSKI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 20, 2022, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction and To Strike as to Tax Year 2018, on the ground 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 petitioner with respect to taxable year 2018, nor had respondent made any other determination with respect to petitioner's tax year 2018 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner has failed to do so.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction and To Strike as to Tax Year 2018 is granted, and this case is dismissed for lack of jurisdiction as to taxable year 2018. References to that year in the petition and first amended petition are deemed stricken.