Opinion
2610-22S
04-11-2022
DEVON W. KISSINGER & PAULA A. KISSINGER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
On February 22, 2022, a petition was filed commencing the above-docketed matter, which petition was followed on April 7, 2022, by respondent's answer thereto. Attached to the latter were copies of a notice of determination concerning collection action issued to petitioners with respect to the 2015, 2017, 2018, and 2019 years.
According, the premises considered, it is
ORDERED that the Clerk of the Court is directed to add the letter "L" to the docket record and other records of the Court and to process this case to trial or other disposition according to the Lien and Levy Action procedures provided by Rules 330 et seq., Tax Court Rules of Practice and Procedure. It is further
ORDERED that, on or before April 28, 2022, respondent shall file either: (1) An appropriate jurisdictional motion as to the 2020 tax year; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to 2020 and attaching thereto a copy of any supporting documentation.