Opinion
23118-21
02-22-2023
MILK STUDIOS, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On November 30, 2021, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the petition herein was not filed within the time prescribed by the Internal Revenue Code. Although the Court directed petitioner to file an objection, if any, to respondent's motion, petitioner has failed to do so. The record shows that the petition was not timely filed.
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.