Opinion
19647-22
02-07-2023
YOGESH PANDIT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 26, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Also on October 26, 2022, petitioner filed an Objection to respondent's motion.
On December 12, 2022, petitioner filed an Answer and two Briefs in Support of Answer. However, further review indicates that these filings appear to be more akin to Supplements to petitioner's Objection.
Upon due consideration, it is
ORDERED that petitioner's Answer, filed December 12, 2022, is recharacterized as petitioner's Supplement to Objection to Motion to Dismiss for Lack of Jurisdiction. It is further
ORDERED that petitioner's two Briefs in Support of Answer, filed December 12, 2022, are recharacterized as petitioner's Supplements to Objection to Motion to Dismiss for Lack of Jurisdiction.