Opinion
26366-21
02-14-2023
WILLIAM ANDREW HEADD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On November 22, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds that no Notice of Determination Under 7623 Concerning Whistleblower Action that would form the basis for a petition to this Court had been sent to petitioner with respect to taxable years 2018 and 2019, nor had respondent made any other determination with respect to petitioner's tax years 2018 and 2019 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 is granted, and this case is dismissed for lack of jurisdiction.