Opinion
7964-24
08-06-2024
JASON DARBY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Pending before the Court in this deficiency action is respondent's Motion to Dismiss for Lack of Jurisdiction, filed July 9, 2024. On August 5, 2024, petitioner filed an Objection thereto.
The foregoing considered, it is
ORDERED that, on or before August 29, 2024, respondent shall file a reply to petitioner's above-referenced Objection to Motion to Dismiss for Lack of Jurisdiction. Among other things, the reply shall provide the basis, including any supporting documentary evidence, for respondent's contention in his Motion that the 200 SW 85th Ave. Apt. 308 address was, at the time of the mailing of the notice of deficiency, petitioner's last known address within the meaning of Treas. Reg. § 301.6212-2.