Opinion
35601-21
03-01-2022
Michael O. Reed 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 March 1, 2022, on the grounds that: (1) no deficiency notice or other notice of determination was issued to petitioner for taxable years 1998 through 2013, and 2015 through 2021, that would confer jurisdiction upon the Court in this case; and (2) the petition in this case was not filed timely as to the deficiency notice issued to petitioner for taxable year 2014, nor was any other notice of determination issued to petitioner for taxable year 2014 that would confer jurisdiction upon the Court in this case. In his motion to dismiss respondent states that petitioner does not object to the granting of the motion. Taking into account representations contained in the petition,, and for the reasons set forth in respondent's motion, it is, ORDERED that respondent's 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.