Opinion
24119-22S
03-22-2023
STUDIO 332, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On January 3, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. On January 18, 2023, respondent filed a First Supplement to Motion to Dismiss for Lack of Jurisdiction. In respondent's motion, as supplemented, respondent asserts that this case should be dismissed on the grounds that no notice of deficiency was issued to petitioner, nor has respondent made any other determination, concerning petitioner's 2020, 2021, or 2022 tax year that would permit petitioner to invoke the jurisdiction of this Court. Although the Court provided petitioner with an opportunity to file an objection, if any, to respondent's motion, as supplemented, petitioner has not done so.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented, is granted and this case is dismissed for lack of jurisdiction.