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Elliott v. Comm'r of Internal Revenue

United States Tax Court
Mar 13, 2023
No. 5713-21S (U.S.T.C. Mar. 13, 2023)

Opinion

5713-21S

03-13-2023

KAREN M. ELLIOTT & PATRICK D. MERRIAM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On March 9, 2023, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioners with respect to taxable year 2017, nor had respondent made any other determination with respect to petitioners' tax year 2017 that would confer jurisdiction on the Court, as of the date the petition herein was filed. In the motion, respondent indicated that petitioners had no objection to the granting thereof.

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.


Summaries of

Elliott v. Comm'r of Internal Revenue

United States Tax Court
Mar 13, 2023
No. 5713-21S (U.S.T.C. Mar. 13, 2023)
Case details for

Elliott v. Comm'r of Internal Revenue

Case Details

Full title:KAREN M. ELLIOTT & PATRICK D. MERRIAM, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Mar 13, 2023

Citations

No. 5713-21S (U.S.T.C. Mar. 13, 2023)