Opinion
19011-22
08-23-2023
EDIE D. GLASS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy Special Trial Judge
Pending before the Court are the Commissioner's Motions to Dismiss for Lack of Jurisdiction, filed June 2, 2023, and June 13, 2023. The Commissioner's motions ask this Court to dismiss this case as to tax years 2011, 2013, and 2016 for lack of jurisdiction on the ground that the petition was filed 3,143; 2,519; and 1,448 days, respectively, after the Notices of Deficiency were sent to Ms. Glass, which was not within the jurisdictional period prescribed by sections 6213(a) or 7502, and to dismiss this case as to tax years 2012, 2014, 2015, and 2019 on the ground that no determination was made as to these taxable periods that would confer jurisdiction on this Court. Ms. Glass filed an objection to the Motions to Dismiss for Lack of Jurisdiction on June 30, 2023.
Unless otherwise indicated, statutory references are to the Internal Revenue Code, Title 26 U.S.C., in effect at all relevant times.
This case was called for hearing on August 16, 2023, during the Court's August 16, 2023, Washington, District of Columbia, special hearing session. Ms. Glass and counsel for the Commissioner appeared and were heard.
Upon due consideration, and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that the Commissioner's Motions to Dismiss for Lack of Jurisdiction filed June 2, 2023, and June 13, 2023, are taken under advisement.