Opinion
4018-20S
06-02-2021
Erica A. Hartsuff Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On October 7, 2020, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the ground that no valid notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code to form the basis for a petition to this Court, had been issued to petitioner with respect to taxable year 2017. In the motion to dismiss, respondent explained that notice of deficiency had not been properly sent to petitioner's statutory last known address within the meaning of the governing provisions of the Internal Revenue Code. Although the Court afforded petitioner the opportunity to file an objection, if any, to the motion, petitioner has not done so.
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 on the ground that the purported notice of deficiency is invalid.