Opinion
6905-23
06-13-2023
REINALDO SOTO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE
On June 7, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Years 2020 and 2021. Respondent asserts in his motion that no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2020 and 2021 tax years.
Upon due consideration, it is
ORDERED that, on or before July 5, 2023, 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 of this case for lack of jurisdiction.
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