Adams v. Comm'r of Internal Revenue

Full title: PAUL H. ADAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: May 24, 2023

No. 18797-22S (U.S.T.C. May. 24, 2023)

Opinion

18797-22S

05-24-2023

PAUL H. ADAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan Chief Judge

ORDER

Kathleen Kerrigan Chief Judge

In the Petition filed to commence this case on August 24, 2022, petitioner seeks review of a purported notice of determination concerning collection action issued to petitioner on July 25, 2022, for the taxable year 2018. However, no such notice of determination is attached to the Petition.

In the Answer, filed October 11, 2022, respondent denies that a notice of determination concerning collection action for the taxable year 2018 has been issued to petitioner. Rather, respondent alleges that a notice of deficiency was issued to petitioner on April 12, 2021. However, no such notice of deficiency is attached to the Answer.

In consideration of the foregoing, it is

ORDERED that, on or before June 14, 2023, respondent shall file (1) a response to this Order, attaching thereto a complete copy of the notice of deficiency upon which this case is based, and (2) an appropriate jurisdictional motion.