Opinion
26568-21S
02-23-2023
MOHAMED E. DOUCOURE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Joseph Robert Goeke Judge
On January 17, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction, on the grounds that the petition was not filed within the time prescribed in the Internal Revenue Code. This case was called from the calendar at the Court's February 6, 2023, Tampa, Florida Trial Session. Both parties appeared and were heard on the pending motion. The record establishes that the petition was not timely filed in this case. See I.R.C. sections 6213(a) and 7502; Hallmark Research Collective v. Commissioner, 150 T.C. ____No. 6 (Nov. 29, 2022). Upon due consideration of the foregoing, and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed January 17, 2023, is granted and this case is dismissed for lack of jurisdiction.