Opinion
18540-21
04-11-2022
TIA CHRISTINE MICHAUD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley, Chief Judge
On January 12, 2022, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the ground that no valid notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code to form the basis for a petition to this Court, had been issued to petitioner with respect to taxable year 2018. In the motion to dismiss, respondent explained that the notice had not been properly sent to petitiner's statutory "last known address". In the petition commencing this proceeding, petitioner had made the substantively identical allegation that the notice was not valid due to the address.
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 on the ground that the purported notice of deficiency is invalid.