Opinion
34482-21S
01-11-2023
VAL K. SHAW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
KATHLEEN KERRIGAN, CHIEF JUDGE
On February 16, 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. On March 1, 2022, respondent filed a Supplement to his motion. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, as supplemented, petitioner 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, as supplemented, is granted and this case is dismissed for lack of jurisdiction.