Opinion
998-23S
10-03-2023
LASHEEDA J. FORNEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge.
This case appears to have been inadvertently commenced when petitioner was attempting to file an amended petition in another case. That other case was closed by a now-final Order of Dismissal for Lack of Jurisdiction. See I.R.C. § 7481(a)(1). However, the petition filed February 8, 2023, was not timely with respect to the notice of deficiency dated August 15, 2022. Organic Cannabis Found., LLC v. Commissioner, 962 F.3d 1082 (9th Cir. 2020); Hallmark Rsch. Collective v. Commissioner, 159 T.C. 126 (2022).
Upon due consideration and for cause, it is
ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction.