Opinion
15115-23S
03-28-2024
BLUDIZE ERICA SENATUS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
By Order served March 1, 2024, (1) as to a notice of deficiency issued for petitioner's 2021 tax year, this case was dismissed for lack of jurisdiction on the grounds that the petition was not filed within the time prescribed in the Internal Revenue Code, and (2) as to a purported notice of determination concerning collection action for petitioner's 2023 tax year, this case was dismissed for lack of jurisdiction on the grounds that no such notice was issued to petitioner that would permit petitioner to invoke the jurisdiction of this Court.
On March 25, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction, asserting that so much of this case relating to a purported notice of deficiency for petitioner's 2023 tax yar should be dismissed for lack of jurisdiction on the grounds that respondent has not issued any such notice that would permit petitioner to invoke the jurisdiction of this Court.
Upon due consideration, it is
ORDERED that, on or before April 19, 2024, petitioner shall file an Objection, if any, to respondent's above-described motion, filed March 25, 2024. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.
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