Opinion
2247-21
04-26-2022
JOSHUA HOLTRY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
Respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground the petitioner paid the deficiency before the issuance of the statutory notice of deficiency. 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.