Opinion
16990-23S
12-14-2023
ERIKA MARTINEZ-GALARZA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE.
On December 13, 2023, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to 2020, on the ground that the petition as to the taxalbe year 2020 was not timely filed within the period prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.). However, further review has raised questions regarding the potential applicability of any disaster relief afforded to California residents, which extended the filing deadline in relevant circumstances to November 16, 2023.
Accordingly, the premises considered, it is
ORDERED that, on or before January 3, 2024, respondent shall file a supplement to the just-referenced motion clarifying the relevance, if any, of disaster relief in the context of this proceeding.