Opinion
13705-23
09-19-2024
MARKUS REED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Emin Toro Judge
On September 13, 2024, respondent filed an unopposed Motion to Dismiss for Lack of Jurisdiction (Doc. 17) on the ground the petition was not filed within the time prescribed by I.R.C. § 6213(a) or § 7502. The Motion provides that "[r]espondent will pursue an administrative resolution for petitioner's 2021 tax liability." The record establishes that the Petition was not timely filed. See I.R.C. §§ 6213(a), 7502; Hallmark Rsch. Collective v. Commissioner, 159 T.C. 126 (2022); Sanders v. Commissioner, No. 15143-22, 161 T.C., slip op. at 7-8 (Nov. 2, 2023). Upon due consideration, it is hereby
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction filed September 13, 2024, is granted, and this case is dismissed for lack of jurisdiction.