Opinion
9178-23L
04-26-2024
RICHARD A. SHAW, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Albert G. Lauber, Judge
Pursuant to the Court's Memorandum Opinion (T.C. Memo. 2024-48) issued in the above-docketed case on April 22, 2024, it is
ORDERED that respondent's Motion to Dismiss for Failure to State a Claim upon Which Relief Can Be Granted, filed February 15, 2024, is granted, and this case is dismissed because the Petition was not filed within the period prescribed by I.R.C. section 6330(d)(1).