Opinion
24664-21
01-06-2023
JASON LEE WERNSING & SARAH JEAN WERNSING, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan Chief Judge
On November 23, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the Petition in this case was not filed within the time prescribed by the Internal Revenue Code. Although the Court directed petitioners to file an objection, if any, to respondent's Motion to Dismiss, petitioners failed to do so. The record shows that the Petition was not timely filed. See I.R.C. §§ 6213(a), 7502; Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022).
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.