Opinion
4975-22S
09-27-2024
LISA LAVERNE WATERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Zachary S. Fried Special Trial Judge.
On September 25, 2024, 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 petitioner does not object to the granting of the motion. The record establishes that the petition was not timely filed. See I.R.C. § 6015(e)(1)(A); Frutiger v. Commissioner, No. 31153-21, 162 T.C., slip op. at 12 (Mar. 11, 2024).
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 because the Petition was not filed within the period prescribed by I.R.C. section 6015(e).