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Harris v. Comm'r of Internal Revenue

United States Tax Court
Dec 27, 2022
No. 19895-22 (U.S.T.C. Dec. 27, 2022)

Opinion

19895-22

12-27-2022

KIMBERELY S. HARRIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge

On September 29, 2022, petitioner filed a First Amended Petition, indicating therein that she seeks review of notices of determination concerning collection action issued for her 2016 and 2018 tax years. In the petition, however, petitioner also makes allegations concerning her 2020 and 2021 tax years.

On December 2, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that, as to tax years 2016 and 2018, no notice of determination concerning collection action was issued, nor has respondent made any other determination, that would permit petitioner to invoke the jurisdiction of this Court. Respondent's motion, however, does not, address petitioner's allegations concerning her 2020 and 2021 tax years.

Upon due consideration of the foregoing, it is

ORDERED that, on or before January 26, 2023, respondent shall file a supplement to his Motion to Dismiss for Lack of Jurisdiction and therein address petitioner's allegations concerning her 2020 and 2021 tax years. It is further

ORDERED that the Court's Order, served December 21, 2022, directing petitioner to file an Objection, if any, to respondent's above-referenced motion on or before January 19, 2022, will be held in abeyance pending further direction by the Court.


Summaries of

Harris v. Comm'r of Internal Revenue

United States Tax Court
Dec 27, 2022
No. 19895-22 (U.S.T.C. Dec. 27, 2022)
Case details for

Harris v. Comm'r of Internal Revenue

Case Details

Full title:KIMBERELY S. HARRIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Dec 27, 2022

Citations

No. 19895-22 (U.S.T.C. Dec. 27, 2022)