Opinion
6347-22
01-12-2023
RHONDA OLLEANE ALEXANDER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On March 28, 2022, petitioner filed the petition seeking review of a notice of deficiency dated March 21, 2022, issued to her for tax years 2019 and 2020. On May 12, 2022, respondent filed the Answer and attached thereto a notice of deficiency dated March 21, 2022, issued to petitioner for tax year 2019. On August 25, 2022, petitioner filed a Letter and attached thereto a notice of deficiency dated August 1, 2022, issued to her for tax year 2020. The petition filed to commence this case appears to be premature with respect to the notice of deficiency issued to petitioner for tax year 2020.
Upon due consideration, it is
ORDERED that, on or before February 3, 2023, respondent shall file either: (1) an appropriate jurisdictional motion or (2) a response to this Order addressing the basis for the Court's jurisdiction as to tax year 2020 and attaching thereto a copy of any pertinent notice that was issued to petitioner.