Opinion
23174-22S
01-12-2023
KENNETH STEVEN HEARD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On December 22, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Upon review of that Motion, the Court notes that, although the Motion states that a copy of a U.S. Postal Service Form 3877 has been attached as Exhibit A, no such document appears to have been so attached. Rather, the only document to have been attached to the Motion appears to be a copy of the Notice of Deficiency upon which this case is based.
Accordingly, it is
ORDERED that, on or before Feb. 2, 2023, respondent shall file a supplement to his above-referenced Motion to Dismiss, attaching thereto a postmarked U.S. Postal Service Form 3877, or other proof of mailing, showing that the Notice of Deficiency dated October 7, 2020, issued for petitioner's 2017 taxable year, and upon which this case is based, was sent by certified or registered mail to petitioner at his last known address on or about October 7, 2020.