Opinion
1857-23
08-08-2023
TROY RAYMOND KELLERHALS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On April 12, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency and no notice of determination concerning collection action was issued to petitioner for tax years 2020 or 2021, 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, 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.