Opinion
11808-20
04-06-2022
ERIC HALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Albert G. Lauber, Judge
On October 14, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction contending that petitioner did not timely petition this Court within 90 days after a valid notice of deficiency was mailed. See I.R.C. §§ 6212, 6213(a). On November 12, 2021, petitioner objected to respondent's Motion. On November 30, 2021, respondent filed a reply representing that the parties expect to resolve this case administratively. By Order served December 8, 2021, we held the Motion in abeyance and directed the parties to file a status report by April 8, 2022.
On April 1, 2022, the parties filed a joint status report representing that petitioner reached a settlement with the IRS Appeals Office and that petitioner has accordingly withdrawn his objection to the Motion to Dismiss. In consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed October 14, 2021, is granted, and this case is dismissed for lack of jurisdiction.