Opinion
14859-23L
12-27-2023
CLINTON P. SCHOUEST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On December 21, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Years 2011, 2012, 2013, 2014, 2015, 2016, 2018, and 2019 and To Strike. Respondent asserts in his motion that no notice of deficiency or notice of determination concerning collection action sufficient to confer jurisdiction on this Court as to petitioner's 2011, 2012, 2013, 2014, 2015, 2016, 2018, and 2019 tax years was issued to petitioner.
Upon due consideration, it is
ORDERED that, on or before January 19, 2024, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to petitioner's 2011, 2012, 2013, 2014, 2015, 2016, 2018, and 2019 tax years. Petitioner is advised that respondent's motion does not seek dismissal of so much of this case relating to the notice of determination concerning collection action issued for petitioner's 2017 tax year.