Opinion
10478-22
05-17-2023
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On June 29, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground the petition was not filed within the time prescribed by the Internal Revenue Code. Respondent filed a supplement on April 14, 2023. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners failed to do so. The record establishes that the petition was not timely filed.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as supplemented is granted and this case is dismissed for lack of jurisdiction.