Opinion
23841-21
11-22-2021
Akiko Yamaguchi Petitioner v. Commissioner of Internal Revenue Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Maurice B. Foley, Chief Judge
On October 20, 2021, 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. On November 18, 2021, petitioner filed a Letter Dated October 20, 2021, stating she does not dispute the proposed tax liability for tax year 2018 determined against her by respondent.
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.