Opinion
14900-24L
11-12-2024
JEREMY BOWMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On November 8, 2024, respondent filed in the above-docketed matter a Motion To Dismiss for Lack of Jurisdiction, wherein respondent seeks dismissal in part insofar as relates to the Decision Letter on Equivalent Hearing under Internal Revenue Code Sections 6320 and/or 6330, dated August 14, 2024. The premises considered, it is
ORDERED that the November 8, 2024, motion shall be recharacterized as a Motion To Dismiss for Lack of Jurisdiction as to Decision Letter on Equivalent Hearing. It is further
ORDERED that, on or before December 3, 2024, petitioner shall file an objection, if any, to respondent's just-referenced motion. Failure to comply with this Order may result in the granting of respondent's motion and partial dismissal of the instant case as to the decision letter or other appropriate action by this Court. It is further
ORDERED that, on or before December 3, 2024, respondent shall file a supplement to the motion to dismiss and shall attach thereto a copy of the notice of determination regarding lien action referenced in the motion.