Opinion
13839-21
10-12-2021
Joshua David Motto Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction, filed July 30, 2021, on the grounds that no notice of deficiency or notice of determination for tax years 2008 through 2020 was issued to petitioner that would permit petitioner to invoke the jurisdiction of this Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion, petitioner has failed to do so. Taking into account representations contained in the petition, and for the reasons set forth in respondent's motion, it is, ORDERED that respondent's above-referenced motion is granted. It is further
ORDERED that with respect to each year placed in issue in the petition, this case is dismissed for lack of jurisdiction upon the ground stated in respondent's motion.
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