Hall v. Comm'r of Internal Revenue

Full title: SHAUNNA HALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Sep 11, 2023

No. 12056-22 (U.S.T.C. Sep. 11, 2023)

Opinion

12056-22

09-11-2023

SHAUNNA HALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan, Chief Judge.

ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan, Chief Judge.

On June 30, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the Petition was not filed within the time prescribed by the Internal Revenue Code (I.R.C.). Although the Court directed petitioner to file an objection, if any, to respondent's Motion to Dismiss, petitioner failed to do so. The record establishes that the Petition was not timely filed. See I.R.C. sections 6213(a) and 7502; Hallmark Rsch. Collective v. Commissioner, 159 T.C. 126 (2022); Foster v. Commissioner, 445 F.2d 799 (10th Cir. 1971).

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.