Castro v. Comm’r of Internal Revenue

Maurice B. Foley Chief Judge

ORDER OF DISMISSAL FOR LACK OF JURISDICTION

Maurice B. Foley Chief Judge

On November 18, 2020, respondent filed a Motion To Dismiss on the grounds that the petition was not timely filed with respect to the notice of deficiency issued to petitioner for tax year 2018 and no notice of determination concerning collection action was issued to petitioner for tax year 2018 that would confer jurisdiction on this Court. Although the Court directed petitioner to file an objection, if any, to respondent's motion to dismiss, petitioner failed to do so. The record shows that the petition was not timely filed with respect to the notice of deficiency issued to petitioner for tax year 2018 and there is no indication that respondent issued a notice of determination concerning collection action to petitioner for tax year 2018.

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.