Opinion
17511-22SL
06-18-2024
ADAM CHASE TIMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL
Lewis R. Carluzzo, Chief Special Trial Judge.
Because the filing period prescribed in I.R.C. section 6330(d) is not jurisdictional, see Boechler, P.C. v. Commissioner, 596 U.S. 199 (2022), it is
ORDERED that the joint Motion to Dismiss for Lack of Jurisdiction, filed June 14, 2024, in this I.R.C. section 6330(d) case, is recharacterized and treated as a motion to dismiss upon the ground that the petition was not timely filed. Because representations contained in the motion support dismissal on that ground, it is further
ORDERED that the motion is granted, and this case is dismissed.