Opinion
10753-24
08-20-2024
DONNA DAVIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On June 26, 2024, a petition was filed commencing the above-docketed matter, which petition was followed on August 20, 2024, by respondent's answer thereto. However, upon further review, it has come to the Court's attention that the record at present raises multiple jurisdictional issues comprising both the address to which the notice of deficiency was sent and the timeliness of the petition. The answer further indicated that a jurisdictional motion was expected to be forthcoming.
Accordingly, to clarify the record herein insofar as concerns documentation relevant to the Court's jurisdiction over any potential parties and taxable periods, it is
ORDERED that, on or before September 10, 2024, respondent shall file either: (1) An appropriate jurisdictional motion; and/or (2) a report establishing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation.