Opinion
27715-22S
06-05-2023
SIMON COHEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 30, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to 2020 and To Strike. Respondent asserts in his motion that so much of this case relating to tax year 2020 should be dismissed because at the time the petition to commence this case was filed, no notice of deficiency had been issued, nor had respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2020 tax year. See Internal Revenue Code section 6213(a).
Upon due consideration, it is
ORDERED that, on or before June 27, 2023, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to tax year 2020.
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