Opinion
24699-21S
04-21-2022
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley, Chief Judge
On November 24, 2021, respondent filed a motion to dismiss for lack of jurisdiction on the ground that no notice of deficiency or notice of determination sufficient to confer jurisdiction on this Court as to tax year 2015 was issued to petitioner. On February 18, 2022, respondent filed a first supplement to motion to dismiss for lack of jurisdiction asserting that, additionally, respondent had not failed to make a final determination within the time prescribed by the Internal Revenue Code regarding any interest abatement claim by petitioner for tax year 2015. Although the Court provided petitioner the opportunity to file an objection, if any, to respondent's motion, no response has been received from petitioner.
Upon due consideration, it is
ORDERED that respondent's motion to dismiss for lack of jurisdiction, as supplemented, is granted and this case is dismissed for lack of jurisdiction.