Opinion
21027-18L
11-23-2022
AKRAM GENDY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On November 18, 2022, respondent filed a motion to dismiss on ground of mootness. Upon review of the motion, it appears that the civil penalty liabilities listed in the motion do not match the ones in the notice of determination that gave rise to the petition in this case. Upon due consideration, it is
ORDERED that respondent shall, on or before December 7, 2022, file a supplement to the motion to dismiss on ground of mootness addressing the discrepancy between the tax periods listed in the notice of determination and in respondent's motion.