Opinion
33721-21
02-02-2023
CHRISTOPHER J. SMALLWOOD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On January 7, 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 petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so. The record establishes that the petition was not timely filed. 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.