Opinion
16955-21
01-19-2022
Anthony L. Hunt Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On November 12, 2021, respondent filed a motion to dismiss for lack of jurisdiction on the ground that the petition in this case was not filed within the time prescribed by the Internal Revenue Code. The PS Form 3877 attached to that motion to support respondent's assertion concerning the mailing date of the notice of deficiency on which this case is based, however, bears a postmark date that is only partially legible.
Upon due consideration, it is
ORDERED that, on or before February 9, 2022, respondent shall file a supplement to his above-referenced motion and attach thereto legible documentation which substantiates respondent's position concerning the mailing date of the notice of deficiency on which this case is based.