Opinion
12775-20
03-28-2022
Anna T. Balash-Ioannidou Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Albert G. Lauber Judge
This case is calendared on the Court's April 11, 2022, New York, New York, trial session. In November 2020 petitioner filed a petition in which she asserted that she "never received [a] statutory notice of deficiency" or a "statutory notice of determination" for tax years 1991-2019.
On September 2, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Respondent argued, consistently with petitioner's allegations in the petition, that the IRS for 1991-2019 did not issue petitioner any type of notice that would confer jurisdiction on this Court. On March 14, 2022, petitioner filed a Motion for Continuance, but she has not yet responded to the Motion to Dismiss.
In consideration of the foregoing, it is
ORDERED that petitioner's Motion for Continuance, filed March 14, 2022, is granted, and this case is stricken from the Court's April 11, 2022, New York, New York, trial session and is continued. It is further
ORDERED that jurisdiction of this case is retained by the undersigned. It is further
ORDERED that petitioner shall file, on or before April 21, 2022, a response to the Motion to Dismiss for Lack of Jurisdiction. If petitioner does not respond, the Court will likely grant the Motion and dismiss this case for lack of jurisdiction.