Opinion
27302-21S
04-04-2022
MARGO LYN CALDWELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge
On December 8, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the grounds that the petition was not timely filed as to the notice of determination concerning collection action issued for tax year 2016, no notice of deficiency and no notice of determination for disallowance of interest abatement claim was issued to petitioner for tax year 2016, nor has respondent made any other determination with respect to tax year 2016 that would confer jurisdiction on this Court. Respondent did not attached to his motion a copy of the notice of determination concerning collection action that he mailed to petitioners for tax year 2016 or a copy of PS Form 3877 or other proof of mailing of the notice of determination concerning collection action for tax year 2016.
Upon due consideration, it is
ORDERED that, on or before April 25, 2022, respondent shall file a Supplement to his motion to dismiss and shall attach a copy of the notice of determination concerning collection action issued to petitioner for tax year 2016 and a copy of PS Form 3877 or other proof of mailing of the notice of determination concerning collection action for tax year 2016 thereto.
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