Opinion
564-20
06-10-2021
John Groeschner & Marie Groeschner Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On February 18, 2020, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that the petition was not timely filed with respect to a notice of deficiency issued to petitioners for 2017. On March 26, 2020, and May 6, 2020, respondent filed supplements to the motion to dismiss. In respondent's Third Supplement to Motion To Dismiss for Lack of Jurisdiction, filed October 1, 2020, respondent seeks to dismiss this case as to petitioner Marie Groeschner on the ground that no notice of deficiency or other notice of determination was issued to petitioner Marie Groeschner for taxable year 2017 that would permit her to invoke the Court's jurisdiction. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, as supplemented, petitioners failed to do so.
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.