Opinion
23320-21
01-24-2022
Suzanne Vitaletti Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley, Chief Judge
On November 15, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds: (1) As to 2018, that the petition was not filed within the time prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.); and (2) as to 2021, that no notice of deficiency, as authorized by section 6212 and required by section 6213(a), I.R.C., to form the basis for a petition to this Court, had been sent to petitioner with respect to the 20 tax year, nor had respondent made any other determination with respect to such tax year that would confer jurisdiction on the Court, as of the time the petition herein was filed. In the motion, respondent indicates that petitioner has no objection to the granting thereof.
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.