Opinion
32682-21
02-27-2023
WINSTON COUTTIEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On January 19, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that no notice of determination pursuant to section 6320 and/or 6330 of the Internal Revenue Code (I.R.C.), notice of final determination for full or partial disallowance of an interest abatement claim pursuant to section 6404(h), I.R.C., or notice of deficiency pursuant to sections 6212 and 6213, I.R.C., had been sent to petitioner with respect to the taxable years 2020 and 2021, nor had respondent made any other determination with respect to such tax years that would confer jurisdiction on this 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 is granted, and this case is dismissed for lack of jurisdiction.