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Hernandez v. Comm'r of Internal Revenue

United States Tax Court
Mar 13, 2023
No. 18309-22S (U.S.T.C. Mar. 13, 2023)

Opinion

18309-22S

03-13-2023

MARISSA ANNE HERNANDEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On October 4, 2022, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, and a first supplement followed on October 18, 2022. The motion, as supplemented, sought dismissal on the grounds: (1) As to 2020, that the petition was not filed within the time prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.); and (2) as to 2021 and 2022, that no notice of deficiency, as authorized by section 6212 and required by section 6213(a), I.R.C., to form the basis for a petition to this Court, had been sent to petitioner with respect to the 2021 and 2022 tax years, as of the time the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, as supplemented, petitioner has failed to do so.

Upon due consideration, it is

ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction, as supplemented, is granted, and this case is dismissed for lack of jurisdiction.


Summaries of

Hernandez v. Comm'r of Internal Revenue

United States Tax Court
Mar 13, 2023
No. 18309-22S (U.S.T.C. Mar. 13, 2023)
Case details for

Hernandez v. Comm'r of Internal Revenue

Case Details

Full title:MARISSA ANNE HERNANDEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Mar 13, 2023

Citations

No. 18309-22S (U.S.T.C. Mar. 13, 2023)