Opinion
19770-21S
03-17-2022
Kim William Coulter & Aimee Depaulo Coulter Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley, Chief Judge
On September 22, 2021, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. A first supplement to the motion (albeit improperly designated for eFiling purposes) followed on November 26, 2021. In the motion, respondent indicated that petitioners had no objection to the granting thereof. The record shows that the petition was not timely filed.
Upon due consideration, it is
ORDERED that respondent's document filed November 26, 2021, shall be recharacterized as a First Supplement to Motion To Dismiss for Lack of Jurisdiction. It is further
ORDERED that respondent's just-referenced Motion To Dismiss for Lack of Jurisdiction, as supplemented, is granted, and this case is dismissed for lack of jurisdiction. 1