Young v. Comm'r of Internal Revenue

Full title: Gwendolyn Young Petitioner v. Commissioner of Internal Revenue Respondent

Court: United States Tax Court

Date published: Dec 28, 2021

No. 27758-21 (U.S.T.C. Dec. 28, 2021)

Opinion

27758-21

12-28-2021

Gwendolyn Young Petitioner v. Commissioner of Internal Revenue Respondent

Maurice B. Foley, Chief Judge

ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Maurice B. Foley, Chief Judge

On November 26, 2021, respondent filed in the above-docketed case a Motion to Dismiss for Lack of Jurisdiction, on the grounds that no notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioner, nor had respondent made any other determination with respect to petitioner's tax years that would confer jurisdiction on the Court, as of the date the petition herein was filed.

Subsequently, on December 16, 2021, petitioner filed a response to the motion that appeared to concur with the basis of the pending motion and to request that "continuance" from the Court's jurisdiction be expedited. Conversely, the response offered no indication of any notice of deficiency or determination that would support the Court's authority herein.

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.