Opinion
18334-21
01-18-2023
LAURA HEREVIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Pending before the Court is respondent's Motion to Dismiss for Lack of Jurisdiction as to Tax Years 2016 and 2017, filed October 4, 2021. Although the Court directed petitioner to file an objection, if any, to respondent's Motion, no such objection has been filed. The record shows that the Petition was not timely filed with respect to the Notices of Deficiency issued to petitioner for the taxable years 2016 and 2017. See I.R.C. §§ 6213(a), 7502; Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022).
Upon due consideration and for cause, it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction as to the taxable years 2016 and 2017. It is further
ORDERED that so much of this case relating to the taxable years 2016 and 2017is hereby deemed stricken from the Court's record in this case.
Petitioner is informed that the claims raised with respect to the taxable year 2018remain pending before the Court in this case.