Opinion
8803-23
07-19-2023
LINDA GUEST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On July 17, 2023, 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 2022 and 2023, nor had respondent made any other determination with respect to petitioner's tax years 2022 and 2023 that would confer jurisdiction on the Court, as of the date the petition herein was filed. In the motion, respondent indicated that petitioner had no objection to the granting thereof.
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.