Opinion
31555-21
04-05-2022
AUDY ATIGHI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
On January 11, 2022, respondent filed a motion to dismiss for lack of jurisdiction as to tax year 2018 as it relates to a notice of determination concerning collection action, a notice of final determination for disallowance of interest abatement, a notice of determination of worker classification, a notice of determination concerning relief from joint and several liability under section 6015, a notice of certification of seriously delinquent Federal tax debt, and a notice of determination under section 7623 concerning whistleblower action. Respondent's motion does not seek to dismiss so much of this case relating to the notice of deficiency, dated September 7, 2021, issued to petitioner for petitioner's 2018 tax year.
Upon due consideration, it is
ORDERED that, on or before April 27, 2022, petitioner shall file an objection, if any, to respondent's above-referenced motion. Failure to file an objection may result in the granting of respondent's motion.