Opinion
23068-22
03-24-2023
CONSTANCE GARNES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On December 20, 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 petitioner with respect to taxable years 2016 and 2017, nor had respondent made any other determination with respect to petitioner's tax years 2016 and 2017 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner has 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.