Opinion
8399-23
09-26-2023
ORDER
Kathleen Kerrigan Chief Judge.
On September 22, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. That motion references an Exhibit A, which is supposed to be a PS Form 3877 demonstrating the date the notice of deficiency on which this case is based was mailed to petitioner. However, Exhibit A actually appears to be a copy of an account transcript that is unrelated to this case.
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced Motion to Dismiss for Lack of Jurisdiction is deemed stricken from the Court's record. It is further
ORDERED that respondent's above-referenced Motion to Dismiss for Lack of Jurisdiction shall be sealed from view of the public and the parties in this case and shall not be inspected by any person or entity, except by an Order of the Court.
Respondent is free to properly refile his Motion to Dismiss for Lack of Jurisdiction.