Opinion
1628-24S
09-30-2024
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Jennifer E. Siegel, Special Trial Judge.
On September 11, 2024, the Court issued an Order to Show Cause directing the parties to show cause in writing why this case should not be dismissed for lack of jurisdiction on the ground the petition, filed January 31, 2024, was not timely filed in response to the Notice of Deficiency issued April 28, 2023. See, e.g., Hallmark Rsch. Collective v. Commissioner, 159 T.C. 126 (2022). Respondent filed a response, asking that the Court dismiss the case. No response was received from petitioner.
Upon due consideration of the record, and for cause, it is
ORDERED that the Court's Order to Show Cause is made absolute, and this case is dismissed for lack of jurisdiction.