Opinion
22357-21
12-02-2021
Fayette Carvalho Soli Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction, filed November 4, 2024. The motion seeks to dismiss this case on the grounds that: (1) the petition was not timely filed for tax year 2008; (2) no notice of deficiency was issued to petitioner for tax years 1970 through 2019; (3) no notice of determination concerning collection action was issued to petitioner for tax years 1970 through 2007 and 2009 through 2019; and (4) respondent has not made any other determination with respect to tax years 1970 through 2019 that would confer jurisdiction on the Court. Taking into account representations contained in the petition and for the reasons set forth in respondent's motion, it is, ORDERED that respondent's motion is granted. It is further
ORDERED that with respect to each year placed in issue in the petition, this case is dismissed for lack of jurisdiction upon the ground stated in respondent's motion.