Opinion
376-23S
08-02-2023
VICTORIA JEAN HEADRICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge.
The Petition in the above-captioned case seeks review of a purported notice of deficiency for taxable year 2021. On March 9, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no statutory notice of deficiency, as authorized by Internal Revenue Code (I.R.C.) section 6212 and required by I.R.C. section 6213(a) to form the basis for a petition to this Court has been sent to petitioner with respect to taxable year 2021, nor has respondent made any other determination with respect to that taxable year that would confer jurisdiction on this Court. Although the Court directed petitioner to file an objection, if any, to respondent's Motion to Dismiss, petitioner 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.