Brandt v. Comm'r of Internal Revenue

Full title: TIM BRANDT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Jul 19, 2022

No. 20805-21 (U.S.T.C. Jul. 19, 2022)

Opinion

20805-21

07-19-2022

TIM BRANDT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan Chief Judge.

ORDER

Kathleen Kerrigan Chief Judge.

On February 25, 2022, respondent filed in this case a Motion to Dismiss for Lack of Jurisdiction. On April 1, 2022, petitioner filed a Response to Motion to Dismiss for Lack of Jurisdiction.

On May 24, 2022, respondent filed a First Supplement to Motion to Dismiss for Lack of Jurisdiction (first supplement). On June 27, 2022, petitioner filed a Response to First Supplement to Motion to Dismiss for Lack of Jurisdiction, therein stating that he had received a copy of respondent's first supplement on June 9, 2022. Thereafter, on July 15, 2022, petitioner filed a Motion for Extension of Time, stating therein that he requires an extension of time within which to respond to respondent's first supplement because he was not served with a copy of respondent's first supplement. However, petitioner's motion is in direct contradiction to his statement in his response to respondent's first supplement and inconsistent with the fact that petitioner has already filed a response to respondent's first supplement.

Upon due consideration of the foregoing, it is

ORDERED that petitioner's Motion for Extension of Time, filed July 15, 2022, is denied.