Opinion
2982-20S
12-27-2021
Nicholas M. Lozier Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge.
On April 16, 2020, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the grounds that the petition was not timely filed with respect to the notice of deficiency issued to petitioner for tax year 2015 and no notice of determination concerning collection action was issued to petitioner for tax year 2015 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. The record shows that the petition was not timely filed with respect to the notice of deficiency issued to petitioner for tax year 2015 and there is no indication that respondent issued a notice of determination concerning collection action to petitioner for tax year 2015.
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.