Opinion
15990-22
04-19-2023
CHAD A. COMERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On September14, 2022, respondent filed in the above-docketed matter a Motion To Dismiss for Lack of Jurisdiction. However, further review shows that such motion appears to conflate applicable statutory bases pertaining to notices of deficiency versus notices of determination concerning collection action. Moreover, the motion fails to address one of the taxable years, i.e., 2018, raised in the underlying petition.
Accordingly, upon due consideration, and to clarify the record herein, it is
ORDERED that, on or before May 10, 2023, respondent shall file a supplement to the just-referenced motion to dismiss, addressing therein the jurisdictional status of this case as to the 2018 tax year and the statutory bases for any relief sought as to relevant notices or lack thereof.