Opinion
13299-23
11-17-2023
WANDA MANLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On October 31, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction, asserting that this Court has no jurisdiction of this case as no notice of determination concerning collection action was issued to petitioner for her 2019 tax year. In support of his motion, respondent cites to the recent case of Organic Cannabis Found., LLC v. Commissioner, 161 T.C.___ (Sept. 27, 2023).
Upon due consideration of the foregoing, it is
ORDERED that, on or before December 11, 2023, respondent shall file a supplement to his above-described motion and more fully address his position with respect to the Court's holding in the above-cited case of Organic Cannabis and its application to this case.