Opinion
5673-24S
08-15-2024
AMANDA DUGAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge
Pending in this case is Respondent's Motion to Dismiss for Lack of Jurisdiction, filed July 3, 2024 (motion). On July 10, 2024, petitioner filed an Objection to Motion to Dismiss for Lack of Jurisdiction and on August 12, 2024, respondent filed a Response to Objection to Motion to Dismiss for Lack of Jurisdiction. By Order served August 15, 2024, respondent's motion was assigned the undersigned for disposition.
After reviewing the record in this case, the Court believes reviewing a copy of the administrative record will aid in its decision on respondent's motion. Accordingly, the Court will direct the parties to file a stipulated administrative record or respondent shall file the entire administrative record appropriately certified as to its genuineness. The Court will also permit petitioner, if petitioner asserts that the administrative record filed as ordered is not complete, to file a motion to complete or supplement the record. After the complete administrative record is filed, the Court will act on respondent's motion.
Upon due consideration and for cause, it is
ORDERED that on or before September 16, 2024, the parties shall comply with Rule 93(a) and either file a stipulated administrative record or respondent shall file the entire administrative record appropriately certified as to its genuineness. It is further
ORDERED that if petitioner asserts that the administrative record filed as ordered is not complete, petitioner may move on or before September 30, 2024, to complete or supplement the record.
Petitioner is reminded of the free legal help available through the following clinic:
University of Washington School of Law Federal Tax Clinic William H. Gates Hall, Suite 265 P.O. Box 85110 Seattle, WA 98145 206-685-6805