Opinion
559-24S
05-17-2024
JENNIFER CHURCHWELL & DAVID CHURCHWELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On January 11, 2024, petitioners filed the Petition to commence this case, indicating therein that they seek review of a notice of deficiency related to their 2023 tax year. Petitioners, however, attached to the Petition a copy of a notice of deficiency issued for their 2021 tax year. On March 1, 2024, respondent filed an Answer, asserting that only a notice of deficiency for petitioners' 2021 tax year is properly at issue in this case.
On March 14, 2024, the parties filed for the Court's consideration a Proposed Stipulated Decision which addresses only the notice of deficiency issued for petitioners' 2021 tax year.
Upon due consideration of the foregoing, it is
ORDERED that, on or before June 6, 2024, respondent shall file an appropriate jurisdictional motion with respect to so much of this case relating to a notice of deficiency for petitioners' 2023 tax year. We will hold the parties' Proposed Stipulated Decision pending further action by the Court.