Opinion
11632-21L
08-24-2021
Edward L. Filby Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On August 16, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that no notice of determination concerning collection action was issued to petitioner for tax year 2020. Petitioner attached to his petition a notice of determination concerning collection action for tax year 2018.
Upon due consideration, it is
ORDERED that, on or before September 14, 2021, respondent shall file a Supplement to his motion in which he states whether the Court has jurisdiction as to the notice of determination concerning collection action issued to petitioner for tax year 2018.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you currently file in paper and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov.