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Mckernan v. Comm'r of Internal Revenue

United States Tax Court
Mar 29, 2023
No. 25268-22S (U.S.T.C. Mar. 29, 2023)

Opinion

25268-22S

03-29-2023

JOHN A. MCKERNAN, JR. & DONNA MCKERNAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On January 19, 2023, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioners with respect to taxable year 2021, nor had respondent made any other determination with respect to petitioners' tax year 2021 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner has 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.


Summaries of

Mckernan v. Comm'r of Internal Revenue

United States Tax Court
Mar 29, 2023
No. 25268-22S (U.S.T.C. Mar. 29, 2023)
Case details for

Mckernan v. Comm'r of Internal Revenue

Case Details

Full title:JOHN A. MCKERNAN, JR. & DONNA MCKERNAN, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Mar 29, 2023

Citations

No. 25268-22S (U.S.T.C. Mar. 29, 2023)