Opinion
13329-22S
06-26-2023
ROY DAVIDSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On June 23, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Therein, respondent moves that this case be dismissed for lack of jurisdiction as to the taxable year 2018 on the ground that, with respect to the Notice of Deficiency issued to petitioner for that year, the Petition was not filed within the time prescribed by the Internal Revenue Code.
In consideration of the foregoing, it is
ORDERED that respondent's above-referenced Motion is recharacterized as respondent's Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2018. It is further
ORDERED that, on or before July 17, 2023, petitioner shall file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2018. Failure to comply with this Order may result in the granting of the Motion to Dismiss.