Opinion
12347-22S
09-01-2022
DEANNE MICHELE FINLEY & ANTHONY PAUL FINLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On May 23, 2021, petitioners filed the petition in this case seeking review of a purported notice of deficiency issued to them for tax year 2019. On July 22, 2022, respondent filed the Answer attached thereto a notice of deficiency issued to petitioners for tax year 2019 dated June 13, 2022. The petition filed to commence this case appears to be premature with respect to the notice of deficiency issued to petitioners for tax year 2019. Petitioners have until September 12, 2022, to file a new petition with the Court to dispute the notice of deficiency issued to them for tax year 2019.
Upon due consideration, it is
ORDERED that, on or before September 23, 2022, respondent shall file either: (1) an appropriate jurisdictional motion; or (2) a response to this Order addressing the basis for the Court's jurisdiction as to tax year 2019 and attaching thereto a copy of any pertinent notice that was issued to petitioners.