Opinion
8215-22S
04-06-2023
SUSANNE I. SMITH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Peter J. Panuthos Special Trial Judge
On February 27, 2023, respondent filed with the Court a Motion to Dismiss for Lack of Jurisdiction. When this case was called from the calendar for the Trial Session of the Court at San Francisco, California on March 20, 2023, there was no appearance by or on behalf of petitioner. Counsel for respondent appeared and was heard.
Upon due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction filed February 27, 2023, is granted due to no notice of deficiency or determination was issued to petitioner for the 2018 tax year.