Opinion
12404-24S
08-28-2024
NEIL T. MIDTLYNG & DEBORAH M. STONE MIDTLYNG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
Upon due consideration of respondent's Motion to Dismiss for Lack of Jurisdiction, filed August 27, 2024; there being no objection to the granting of that Motion; and for cause, it is
ORDERED that respondent's above-referenced Motion is granted, and this case is dismissed for lack of jurisdiction because the Petition was not filed within the period prescribed by section 6213(a) of the Internal Revenue Code.