Opinion
33902-21
01-20-2023
RAMOND WILSON & DANA EDWARDS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge.
On January 31, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground the petition was not filed within the time prescribed in the Internal Revenue Code. Respondent states in the motion to dismiss that petitioners do not object to the granting of the motion. The record establishes that the petition was not timely filed. See I.R.C. sections 6213(a) and 7502; Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022).
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.