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.