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Finley v. Comm'r of Internal Revenue

United States Tax Court
Mar 8, 2023
No. 12347-22S (U.S.T.C. Mar. 8, 2023)

Opinion

12347-22S

03-08-2023

DEANNE MICHELE FINLEY & ANTHONY PAUL FINLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On September 22, 2022, 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 2019, nor had respondent made any other determination with respect to petitioners' tax year 2019 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so.

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. It is further

ORDERED that the Proposed Stipulated Decision, filed August 30, 2022, is hereby deemed stricken from the Court's record in this case.


Summaries of

Finley v. Comm'r of Internal Revenue

United States Tax Court
Mar 8, 2023
No. 12347-22S (U.S.T.C. Mar. 8, 2023)
Case details for

Finley v. Comm'r of Internal Revenue

Case Details

Full title:DEANNE MICHELE FINLEY & ANTHONY PAUL FINLEY, Petitioners v. COMMISSIONER…

Court:United States Tax Court

Date published: Mar 8, 2023

Citations

No. 12347-22S (U.S.T.C. Mar. 8, 2023)