Opinion
12769-21S
11-22-2021
Kewonda Yvonne Carr Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On April 14, 2021, petitioner filed the petition to commence this case, indicating therein that she seeks review of notices of deficiency and notices of determination concerning collection action issued for her 2017, 2018, and 2019 tax years. On October 14, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2017 and To Strike on the ground that, as to a notice of deficiency for petitioner's 2017 tax year, the petition was not filed within the time prescribed by the Internal Revenue Code. Respondent states that petitioner has no objection to the granting of the motion. The Court notes, however, that respondent's motion does not address this Court's jurisdiction in relation to a notice of determination concerning collection action for petitioner's 2017 tax year.
Upon due consideration, it is
ORDERED that, on or before December 14, 2021, respondent shall file a supplement to his above-referenced motion and therein address the jurisdiction of this Court with respect to a notice of determination concerning collection action for petitioner's 2017 tax year. 1