Opinion
21970-21S
04-21-2022
MARK STEFAN DZIEMIANOWICZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
On January 13, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction (motion to dismiss) on the ground that the petition in this case was not filed within the time prescribed by the Internal Revenue Code. On January 28, 2022, petitioner submitted a document which was filed by the Court as a Response to Motion to Dismiss for Lack of Jurisdiction. Petitioner's response, however, does not address the jurisdictional allegations made by respondent in his motion to dismiss.
Upon due consideration, it is
ORDERED that, on or before May 9, 2022, petitioner shall file a supplement to his Response to Motion to Dismiss for Lack of Jurisdiction and therein address respondent's allegations set forth in the above-referenced motion to dismiss concerning the late filing of the petition with respect to the notice of deficiency issued for petitioner's 2018 tax year.
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