Opinion
7538-20
06-02-2021
Jana Alia San Miguel Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On October 7, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2020 and To Strike, on the ground 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 year 2020, nor had respondent made any other determination with respect to petitioner's tax year 2020 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, petitioner has failed to do so.
Upon due consideration, it is
ORDERED that respondent's Motion To Dismiss for Lack of Jurisdiction as to Taxable Year 2020 and To Strike is granted, and this case is dismissed for lack of jurisdiction as to taxable year 2020. References to that year in the petition are deemed stricken. The case will continue before the Court as to taxable year 2017.