Opinion
1982-21
03-15-2022
CHUCK PATTISON & C. ZDANOWSKI-PATTISON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Joseph W. Nega Judge
This case is calendared for a remote trial at the session of the Court scheduled to commence on May 23, 2022, for cases in which Buffalo, New York, is the place of trial.
On March 4, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to 2018 upon the ground that no statutory notice of deficiency, as authorized by I.R.C. §§ 6212 and 6213(a) to form the basis for a petition to this Court, has been sent to petitioners. Additionally, respondent indicates that respondent was unable to determine petitioners' views regarding the granting of respondent's Motion to Dismiss for Lack of Jurisdiction as to 2018 filed on March 4, 2022.
Upon due consideration, it is
ORDERED that, on or before April 14, 2022, petitioners shall file a response to respondent's Motion to Dismiss for Lack of Jurisdiction as to 2018 filed March 4, 2022.