Opinion
2659-23S
04-25-2023
MANDRELL JERMAINE ANDERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On March 6, 2023, petitioner filed the petition to commence this case, indicating therein that petitioner seeks review of a notice of deficiency issued to petitioner for the 2021 tax year. No notice of deficiency or notice of determination is attached to the petition.
On April 24, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction, asserting that as to a notice of deficiency issued to petitioner for petitioner's 2020 tax year this case should be dismissed for lack of jurisdiction on the grounds the petition was not filed within the time prescribed in the Internal Revenue Code. Respondent's motion, however, does not address petitioner's 2021 tax year.
Upon due consideration, it is
ORDERED that, on or before May 16, 2023, respondent shall file a supplement to his Motion to Dismiss for Lack of Jurisdiction addressing this Court's jurisdiction with respect to petitioner's 2021 tax year.