Opinion
10127-24S
09-12-2024
CHARLES L. COX & DENAN H. COX, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Petitioner filed the petition in this case on June 12, 2024, seeking review of a notice of determination concerning collection action and a notice of determination for disallowance of interest abatement claim for tax year 2015. On August 20, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was filed late as to the notice of deficiency issued to petitioners for tax year 2015. In his motion, respondent did not address whether the Court has jurisdiction with respect to a notice of determination concerning collection action or notice of determination for disallowance of interest abatement claim issued to petitioners for tax year 2015.
Upon due consideration, it is
ORDERED that, on or before October 3, 2024, respondent shall file a Supplement to his Motion to Dismiss for Lack of Jurisdiction. In that supplement, respondent shall set forth and discuss fully respondent's position as to whether the Court has jurisdiction as to a notice of determination issued to petitioners for tax year 2015.