Opinion
31015-21
04-26-2022
MOLILIN DY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley, Chief Judge.
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction, filed January 7, 2022, on the ground that no notice of deficiency or notice of determination sufficient to confer jurisdiction on this Court was issued to petitioner for tax years 2004 through 2020. Although the Court provided petitioner the opportunity to file an objection, if any, to respondent's motion, no response has been received from petitioner.
Taking into account statements made in the petition and for reasons set forth in respondent's motion, it is
ORDERED that respondent's above-referenced motion is granted. It is further
ORDERED that with respect to each year placed in issue in the petition, this case is dismissed for lack of jurisdiction upon the ground stated in respondent's motion.
Petitioner's attention is invited to Internal Revenue Code section 6673. That section authorizes the Court to require a taxpayer to pay to the United States a penalty not in excess of $25,000 whenever it appears that proceedings have been instituted or maintained by the taxpayer(s) primarily for delay or that the position of the taxpayer(s) in such proceeding is frivolous or groundless. Petitioner is admonished that the Court will consider imposing such a penalty in future cases commenced by petitioner seeking similar relief under similar circumstances.