Opinion
21622-21
01-31-2022
Justin MacFarland & Shaun MacFarland Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On November 16, 2021, 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 petitioners for tax year 2013 and no notice of deficiency was issued to petitioners for tax years 2014 through 2017 that would confer jurisdiction on this Court. Respondent states in the motion that petitioners does not object to the granting of this motion. The record shows that the petition was not timely filed with respect to the notice of deficiency issued to petitioners for tax year 2013 and there is no indication that respondent issued a notice of deficiency to petitioners for tax years 2014 through 2017.
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.