Opinion
13698-23
01-22-2024
ARLINGTON A. HEYLIGAR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On October 18, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency, notice of determination concerning collection action, or notice of determination concerning whistleblower action was issued to petitioner for tax years 2021, 2022, or 2023, nor has respondent made any other determination with respect to those years that would confer jurisdiction on this Court. Although the Court directed petitioner to file an objection to respondent's motion to dismiss, petitioner failed to do so.
Also pending in this case is petitioner's Motion to Proceed Remotely filed October 10, 2023.
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. It is further
ORDERED that petitioner's above-referenced Motion to Proceed Remotely is denied as moot.