Opinion
11228-20
06-09-2021
Roger S. Davis Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On November 9, 2020, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the petition herein was not filed within the time prescribed by the Internal Revenue Code. A first supplement to the motion followed on November 20, 2020. Although the Court directed petitioner to file an objection, if any, to respondent's motion, petitioner has failed to do so. The record shows 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.