Opinion
26580-21S
04-05-2022
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On December 30, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds: (1) As to 2018 and 2017, that the petition was not filed within the time prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.), nor had respondent made any other determination with respect to such tax years that would confer jurisdiction on the Court; and (2) as to 2016, 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 2016 tax year, nor had respondent made any other determination with respect to such tax year that would confer jurisdiction on the Court, as of the time the petition herein was filed. In the motion, respondent indicates that petitioner has no objection to the granting thereof.
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.