Herrera v. Comm'r of Internal Revenue

Full title: ADELA HERRERA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Apr 25, 2023

No. 18093-22S (U.S.T.C. Apr. 25, 2023)

Opinion

18093-22S

04-25-2023

ADELA HERRERA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan, Chief Judge

ORDER

Kathleen Kerrigan, Chief Judge

This case is scheduled for trial at the Court's June 20, 2023, Los Angeles, California trial session. On April 21, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction insofar as it relates to the taxable year 2021, upon the ground that no statutory notice of deficiency as authorized by I.R.C. § 6212 and required by § 6213(a) to form the basis of the 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 taxable year 2021 that would confer jurisdiction on this Court. Upon due consideration, it is

ORDERED that respondent's Motion to Dismiss is granted, and this case is dismissed for lack of jurisdiction insofar as it relates to taxable year 2021.