Opinion
22942-22
11-07-2023
HEATHER B. VRABEL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Courtney D. Jones, Judge.
This case is on the calendar of the Court's November 27, 2023, trial session for Dallas, Texas. On November 6, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that: (i) the petition was not filed within the time prescribed by I.R.C. § 6213(a); (ii) no notice of determination has been issued to petitioner under I.R.C. § 6320 or § 6330 for taxable year 2014; and (iii) the petition is premature under I.R.C. § 6015(e) regarding petitioner's attempt to request innocent spouse relief for the 2014 tax year. Respondent represents that petitioner has no objection to the granting of the motion.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction (Doc. 12), is granted, and this case is dismissed for lack of jurisdiction.