Opinion
16564-23
04-17-2024
ANA G. PADILLA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge.
On February 7, 2024, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, and a first supplement to the motion followed on March 1, 2024. The motion, as supplemented, sought dismissal, 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 years 2020, 2021, and 2022, nor had respondent made any other determination with respect to petitioner's tax years 2020, 2021, and 2022, including any notice of final determination for disallowance of interest abatement claim or notice of final determination concerning relief from joint and several liability, that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, as supplemented, petitioner has failed to do so.
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. It is further
ORDERED that, in addition to regular service, the Clerk of the Court shall serve a copy of this Order on petitioner at 2406 Ruffin Dr., Fredericksburg, VA 22408.