Opinion
12218-20S
12-16-2021
Ronnie Lee Thomas Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION\
Maurice B. Foley, Chief Judge
On February 3, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction, requesting therein that this case be dismissed on the following grounds: (1) no notice of deficiency or notice of final determination for disallowance of an interest abatement claim (or failure of IRS to make final determination within 180 days after claim for abatement) has been issued to petitioner for the taxable years 2011, 2012, 2013, 2014, and 2015; and (2) respondent has not made any other determination for such taxable years that would confer jurisdiction on the Court in this case. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so. A review of the record in this case reveals no indication that respondent has made any determination that would invoke this Court's jurisdiction over petitioner's 2011, 2012, 2013, 2014, and 2015 taxable years.
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced motion is granted, and this case is dismissed for lack of jurisdiction.