Opinion
22112-21
02-07-2022
Vicki J. Davis & James L. Davis Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley, Chief Judge
On November 24, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground the petition was not filed within the time prescribed in the Internal Revenue Code. Respondent states in the motion to dismiss that petitioners do not object to the granting of the motion. 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 is granted and this case is dismissed for lack of jurisdiction.