Opinion
7628-21S
01-12-2022
Dianne Hastings Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On July 23, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction and as to Tax Years 2020 and 2021, on the ground 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 2020 and 2021, nor had respondent made any other determination with respect to petitioner's tax years 2020 and 2021 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner has failed to do so.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction and To Strike as to Tax Years 2020 and 2021 is granted, and this case is dismissed for lack of jurisdiction as to taxable years 2020 and 2021. References to those years in the petition are deemed stricken.