Opinion
21091-21
07-05-2022
DAVID C. TONEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Upon due consideration of respondent's Status Report filed July 1, 2022, petitioner's Reply to respondent's status report filed July 5, 2022, and the recitals therein concerning the present status of this case, it is
ORDERED that, on or before September 6, 2022, respondent shall (1) either file an appropriate jurisdictional motion, or (2) a further report concerning the then present status of this case, including whether a deficiency notice for tax years 2016 and/or 2019 was issued to petitioner that would confer jurisdiction upon the Court.