Opinion
1618-24
08-02-2024
LAVONICA NEWELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On June 21, 2024, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction and to Strike as to the Taxable Year 2022 on the grounds that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioner with respect to taxable year 2022, nor had respondent made any other determination with respect to that tax year that would confer jurisdiction on the Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion, petitioner has failed to do so.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction and to Strike as to the Taxable Year 2022 is granted in that so much of this case relating to tax year 2022 is dismissed for lack of jurisdiction and deemed stricken from the Court's record.