Opinion
11118-23
12-19-2023
TAMMY L. GILES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 13, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction and to Strike. Therein respondent moved that this case, insofar as it purports to a dispute a notice of deficiency for tax year 2022 and/or a notice of determination concerning collection action for any taxable year, be dismissed for lack of jurisdiction on the grounds that no notice of deficiency was issued to petitioner for 2022, nor was a notice of determination issued to petitioner for any year. However, respondent acknowledges that petitioner was sent a notice of deficiency for tax year 2021, a copy of which was attached to the Petition.
Upon due consideration, and for cause, it is
ORDERED that, on or before January 19, 2024, petitioner shall file an objection, if any, to respondent's above-referenced Motion. Failure to file a timely objection may result in the granting of respondent's Motion.