Opinion
10979-23S
04-11-2024
MICHAEL GIBBS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On July 10, 2023, petitioner filed the Petition to commence this case, indicating therein that he seeks review with respect to a notice of deficiency issued for his 2022 and 2023 tax years. No notice of deficiency is attached to the Petition.
On August 23, 2023, respondent filed an Answer to the Petition, therein asserting that only a notice of deficiency issued for petitioner's 2021 tax year is properly at issue in this case. Respondent attached a copy of a notice of deficiency issued to petitioner for his 2021 tax year.
On April 10, 2024, the parties filed a Proposed Stipulated Decision which addresses only petitioner's 2021 tax year. However, respondent has not filed in this case an appropriate jurisdictional motion with respect to petitioner's 2022 and 2023 tax years.
Upon due consideration of the foregoing, it is
ORDERED that, on or before May 2, 2024, respondent shall file an appropriate jurisdictional motion with respect to petitioner's 2022 and 2023 tax years. The Court will hold the parties' Proposed Stipulated Decision.