Opinion
175-23
03-29-2023
STACEY CAVAGNUOLO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 4, 2023, petitioner filed the petition to commence this case, indicating that she seeks review of a notice of determination concerning relief from joint and several liability under section 6015 issued for her "2015-2018" tax years. On March 2, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction, asserting therein that, based upon the notice of determination in this case which was issued as to petitioner's 2015, 2017, and 2018 tax years, this case should be dismissed because the petition was not timely filed. Respondent's motion, however, does not address petitioner's 2017 tax year.
Upon due consideration of the foregoing, it is
ORDERED that, on or before April 19, 2023, respondent shall file a supplement to his above-referenced motion and therein address whether this Court has jurisdiction with respect to petitioner's 2016 tax year.