Opinion
4351-21
12-23-2021
Nazario Maya Soto & Susana Lozano Padilla Petitioners v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley Chief Judge
On May 10, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the grounds that the petition was not timely filed with respect to the notice of deficiency issued to petitioners for tax year 2016 and no notice of deficiency was issued to petitioners for tax years 2017 and 2018 that would confer jurisdiction on this Court. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners failed to do so. The record shows that the petition was not timely filed with respect to the notice of deficiency issued to petitioners for tax year 2016 and there is no indication that respondent issued a notice of deficiency to petitioners for tax years 2017 and 2018.
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.