Opinion
5669-23
06-05-2023
BETSEY LYNN GARROW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 31, 2023, petitioner filed the petition to commence this case indicating therein that she seeks review of a notice of deficiency issued for her 2023 tax year. However, petitioner attached to the petition a notice of deficiency that was issued for her 2021 tax year. On May 24, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2023. 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 2023 tax year.
Upon due consideration, it is
ORDERED that, on or before June 26, 2023, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to tax year 2023. Petitioner is advised that respondent's motion does not seek dismissal of so much of this case relating to the notice of deficiency issued for petitioner's 2021 tax year.
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