Opinion
27760-21S
06-08-2023
MARK F. COBLE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Pending before the Court in the above-docketed matter is respondent's Motion to Dismiss for Lack of Jurisdiction, filed March 28, 2022, as supplemented. On September 19, 2022, petitioner filed a Response to respondent's First Supplement to Motion to Dismiss for Lack of Jurisdiction, filed September 13, 2022.
Upon due consideration of the foregoing, it is
ORDERED that, on or before July 10, 2023, respondent shall file an additional supplement to the above-referenced Motion to Dismiss for Lack of Jurisdiction. Respondent shall attach to such response a copy of a postmarked U.S. Postal Service Form 3877, or other proof of mailing, showing that the Notice of Deficiency issued to petitioner for the taxable year 2006 was sent by certified or registered mail to petitioner at his last known address on or about November 26, 2012, in accordance with I.R.C. § 6212. Respondent shall explain in the supplement the basis for determining petitioner's last known address for purposes of mailing the aforementioned Notice.