Opinion
12528-23
09-29-2023
JONATHAN RIDGEWAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On September 27, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Therein respondent moves that this case be dismissed for lack of jurisdiction upon the ground that no notice of deficiency, as authorized by Internal Revenue Code (I.R.C.), 26 U.S.C. section 6212 and required by I.R.C. section 6213(a) to form the basis for a petition to this Court, has been sent to petitioner, nor has respondent made any other determination with respect to petitioner that would confer jurisdiction on this Court.
Upon due consideration of the above, and for cause, it is
ORDERED that petitioner shall, by October 20, 2023, file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to comply with this Order may result in the granting of respondent's motion and dismissal of the instant case or other appropriate action by this Court.