Opinion
17389-23S
12-22-2023
LEMARC COUSIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 14, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Year 2023 and To Strike. Respondent asserts in his motion that no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2023 tax year.
Upon due consideration, it is
ORDERED that, on or before January 17, 2024, 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 2023. Petitioner is advised that respondent's motion does not seek dismissal of so much of this case relating to the notice of deficiency issued to petitioner for his 2022 tax year.