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Steller v. Comm'r of Internal Revenue

United States Tax Court
Mar 21, 2023
No. 26757-21 (U.S.T.C. Mar. 21, 2023)

Opinion

26757-21

03-21-2023

STEPHEN JOHN STELLER & JORDAN STELLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Kathleen Kerrigan Chief Judge

On December 2, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioners with respect to taxable years 2013 and 2014, nor had respondent made any other determination with respect to petitioners' tax years 2013 and 2014 that would confer jurisdiction on the Court, as of the date the petition herein was filed. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so.

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.


Summaries of

Steller v. Comm'r of Internal Revenue

United States Tax Court
Mar 21, 2023
No. 26757-21 (U.S.T.C. Mar. 21, 2023)
Case details for

Steller v. Comm'r of Internal Revenue

Case Details

Full title:STEPHEN JOHN STELLER & JORDAN STELLER, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Mar 21, 2023

Citations

No. 26757-21 (U.S.T.C. Mar. 21, 2023)