Opinion
2215-21L
11-05-2021
Lawrence C. Busch Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Kathleen Kerrigan Judge.
A petition commencing this case was filed on March 23, 2021. Attached to the petition is a notice of determination concerning collection actions under I.R.C. secs. 6320 or 6330 (notice of determination), dated March 19, 2020, which states that the last day to timely file a petition with the United States Tax Court is within 30 days of the date of the letter. USPS Tracking Information attached to the petition seems to suggest that the notice of determination was misdated, however, this is not clear in the record.
Upon due consideration, it is
ORDERED that the parties shall, on or before November 17, 2021, file a response to this Order addressing the timeliness of the petition in this case. It is further
ORDERED that the joint motion to remand is held in abeyance.