Opinion
16809-22
10-11-2022
JAMES FLYNN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 1, 2022, petitioner filed the petition to commence this case, indicating that, with respect to his 2017, 2018, 2019, and 2020 tax years, he seeks review of notices of deficiency, notices of determination concerning collection action, notices of final determination for disallowance of interest abatement claim (or failure of IRS to make determination within 180 days after claim for abatement), notices of determination concerning relief from joint and several liability under section 6015 (or failure of IRS to make determination within 6 months after election or request for relief), notices of certification of seriously delinquent Federal tax debt to the Department of State, and notices of determination under section 7623 concerning whistleblower action. Petitioner did not attach to the petition any copy of a notice of deficiency or notice of determination sufficient to confer jurisdiction upon this Court.
On September 28, 2022, respondent filed his answer to the petition. Respondent attached to the petition only copies of notices of deficiency issued with respect to petitioner's 2017 tax year.
Accordingly, at this juncture, it is not clear whether this Court has jurisdiction with respect to all the notices and all the tax years set forth by petitioner in his petition.
Upon due consideration of the foregoing, it is
ORDERED that, on or before November 2, 2022, either (1) the parties shall file status reports (preferably a joint report) concerning the then-current status of this case and attach thereto copies of all the notices challenged by petitioner, or (2) respondent shall file an appropriate jurisdictional motion.