Opinion
2179-24S
03-18-2024
PRINCE WOODBURY, III, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
Petitioner filed the Petition to commence this case on February 7, 2024. Petitioner indicates therein that he seeks review of a purported notice of deficiency issued for his 2019 and 2020 tax years. No notice of deficiency is attached to the Petition.
On March 6, 2024, petitioner filed a First Amended Petition and attached thereto a copy of a notice of deficiency, dated February 13, 2024, issued for his 2019 and 2020 tax years. The date of the notice of deficiency indicates that the Petition in this case was prematurely filed and, therefore, this case must be dismissed for lack of jurisdiction. See Internal Revenue Code §6213(a). With respect to the notice of deficiency issued for petitioner's 2019 and 2020 tax years, the Court has commenced a separate case for petitioner at Docket No. 4075-24S as of the date petitioner's First Amended Petition was filed. Accordingly, all future communications concerning that notice of deficiency should be directed to petitioner's case at Docket No. 4075-24S.
Upon due consideration of the foregoing, it is
ORDERED that, on the Court's own motion, this case is dismissed for lack of jurisdiction.