Opinion
3952-24
08-14-2024
VEENA VIJAYAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On April 18, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not timely filed. On May 17, 2024, petitioner filed an Objection to Motion to Dismiss for Lack of Jurisdiction. On June 9, 2024, petitioner filed a First Supplement to her objection. Petitioner's Objection, as supplemented, raises the defense that the notice of deficiency was not sent to her last known address. On July 29, 2024, respondent filed a Response to Objection to Motion to Dismiss for Lack of Jurisdiction, in which he states that he cannot prove that the notice of deficiency was mailed to petitioner's last known address.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is granted in that this case is dismissed for lack of jurisdiction on the ground that respondent did not mail the notice of deficiency to petitioner's last known address.