Opinion
5209-20S
08-05-2021
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On September 15, 2020, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. On October 27, 2020, respondent filed a First Supplement thereto. Although the Court directed petitioner to file an Objection, if any, to respondent's motion to dismiss, as supplemented, petitioner 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, as supplemented, is granted, and this case is dismissed for lack of jurisdiction.