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Fitzpatrick v. Comm'r of Internal Revenue

United States Tax Court
May 18, 2022
No. 12797-21P (U.S.T.C. May. 18, 2022)

Opinion

12797-21P

05-18-2022

HENDRIEKA FITZPATRICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

David Gustafson Judge

The Commissioner filed a motion for summary judgment (Doc. 15), to which petitioner has now filed a response (Doc. 21). It is

ORDERED that, no later than June 17, 2022, the Commissioner shall file a reply. It will be especially helpful if that reply-- (1) addresses in detail the points made in section "3" of the response (beginning, "Now that I have seen the transcript"), and (2) outlines briefly the means by which a taxpayer in petitioner's circumstance--who believes there has been an excessive assessment, but whose liability challenge has been adjudged to be outside the jurisdiction of the Tax Court in a passport case under section 7345--may seek administrative relief outside of the passport case.


Summaries of

Fitzpatrick v. Comm'r of Internal Revenue

United States Tax Court
May 18, 2022
No. 12797-21P (U.S.T.C. May. 18, 2022)
Case details for

Fitzpatrick v. Comm'r of Internal Revenue

Case Details

Full title:HENDRIEKA FITZPATRICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: May 18, 2022

Citations

No. 12797-21P (U.S.T.C. May. 18, 2022)