Opinion
31923-21S
06-12-2023
MIRACLE HART & JERMAINE HART, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On January 3, 2023, 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. Although the Court directed petitioners to file an objection, if any, to the Motion, no such objection has been filed. The record shows that the Petition was not timely filed. See I.R.C. §§ 6213(a); Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022).
In consideration of the foregoing, it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction.