Opinion
19431-22S
10-04-2023
JANELLE KATHLEEN REYNOLDS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Lewis R. Carluzzo Chief Special Trial Judge
This case for the redetermination of a deficiency was called from the calendar for a pretrial conference in Chicago, Illinois, on September 27, 2023. The parties appeared and announced their intention to resolve the matter in a manner consistent with the proposed stipulated decision, filed April 27, 2023.
Premises considered, and for cause set forth more fully in the transcript of the proceedings, it is ORDERED that the Order to Show Cause, served May 15, 2023, is made absolute. It is further
ORDERED that petitioner's motion to proceed remotely, filed September 22, 2022, is moot. Because the petition in this case was not filed within the period prescribed by I.R.C. section 6213(a), it is further
ORDERED that this case is dismissed for lack of jurisdiction.