Opinion
11289-23S
08-07-2023
JAMES FISK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On July 14, 2023, petitioner filed the petition to commence this case, indicating that he seeks review of notice(s) of deficiency issued for his 2021 and 2022 tax years. On August 2, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Year 2022 and To Strike. Respondent asserts in his motion that no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2022 tax year.
Upon due consideration, it is
ORDERED that, on or before August 29, 2023, petitioner shall file a Response, if any, to respondent's above-described motion. Failure to file a response may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to petitioner's 2022 tax year. Petitioner is advised that respondent's motion does not seek the dismissal of so much of this case relating to petitioner's 2021 tax year.