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Reich v. Comm'r of Internal Revenue

United States Tax Court
Mar 6, 2023
No. 712-22S (U.S.T.C. Mar. 6, 2023)

Opinion

712-22S

03-06-2023

STEPHANIE ANNE REICH & STEWART JOHN REICH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On March 23, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground the petition was not filed within the time prescribed by the Internal Revenue Code. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners failed to do so. The record establishes that the petition was not timely filed. See I.R.C. sections 6213(a) and 7502; Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022).

Upon due consideration, it is

ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted and this case is dismissed for lack of jurisdiction.


Summaries of

Reich v. Comm'r of Internal Revenue

United States Tax Court
Mar 6, 2023
No. 712-22S (U.S.T.C. Mar. 6, 2023)
Case details for

Reich v. Comm'r of Internal Revenue

Case Details

Full title:STEPHANIE ANNE REICH & STEWART JOHN REICH, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Mar 6, 2023

Citations

No. 712-22S (U.S.T.C. Mar. 6, 2023)