Nikoley v. Comm'r of Internal Revenue

Full title: UWE NIKOLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Jul 3, 2023

No. 6171-23 (U.S.T.C. Jul. 3, 2023)

Opinion

6171-23

07-03-2023

UWE NIKOLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan Chief Judge

ORDER

Kathleen Kerrigan Chief Judge

Pending before the Court is respondent's Motion to Dismiss for Lack of Jurisdiction, filed June 13, 2023. By Order served June 15, 2023, the Court directed petitioner to file an objection, if any, to that Motion.

On June 30, 2023, petitioner made an electronic filing with the Court, designating the underlying document as a "Motion to Reopen the Record." However, the record in this case is not closed. Moreover, review of aforementioned document shows that it is more akin to an objection to the Motion to Dismiss. That being so, it is

ORDERED that petitioner's Motion to Reopen the Record is recharacterized as petitioner's Objection to Motion to Dismiss for Lack of Jurisdiction.