Opinion
4829-24S
07-17-2024
RAHKMAT ARITIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
Petitioner indicated in the Petition filed to commence this case that petitioner seeks review of a notice of deficiency for tax year 2024. However, the notice of deficiency attached to the Petition was issued for petitioner's 2021 tax year. On July 2, 2024, the parties filed a Proposed Stipulated Decision that addresses only petitioner's 2021 tax year. Thus it appears that this Court lacks jurisdiction of so much of this case relating to petitioner's 2024 tax year.
On July 16, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Tax Year 2024, asserting therein 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 2024 tax year.
Upon due consideration, it is
ORDERED that, on or before August 7, 2024, petitioner shall file an Objection, if any, to respondent's above-described motion. The Court will take appropriate action on the motion following the period for objection. The Court will hold the parties' Proposed Stipulated Decision pending disposition of the respondent's motion.