Opinion
15299-23S
11-03-2023
EBONY ARMSTRONG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 25, 2023, petitioner filed the petition to commence this case, indicating that she seeks to challenge a notice of deficiency, a notice of final determination for disallowance of interest abatement claim (or failure of IRS to make determination within 180 days after claim for abatement) and a notice of determination of worker classification. On November 1, 2023, the parties filed a Proposed Stipulated Decision addressing only a deficiency for petitioner's 2021 tax year. Upon further review, however, it appears that the record does not contain a copy of any notice sufficient to confer jurisdiction on this Court.
Upon due consideration of the foregoing, it is
ORDERED that, on or before November 27, 2023, respondent (the Commissioner) shall file a Response to this Order and attach thereto a copy of the notice of deficiency or notice of determination on which this case is based. The Court will hold the parties' Proposed Stipulated Decision pending submission of that notice. It is further
ORDERED that, on or before November 27, 2023, respondent shall file an appropriate jurisdictional motion with respect to any notice referenced in the petition that is not properly at issue in this case.