Opinion
5727-24S
07-10-2024
JOSEPH E. GLASS & MATTIE PROCACCINI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 10, 2024, petitioners filed the petition seeking to dispute a notice of determination for tax year 2021 and attached thereto a letter related to tax year 2020. Also on April 10, 2024, petitioners filed an Attachment to Petition and attached thereto a notice CP504 for tax year 2020. On May 31, 2024, respondent filed an Answer and attached thereto a notice of deficiency for tax year 2021. On June 14, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction seeking to dismiss petitioner Mattie Procaccini on the ground that no notice of deficiency had been issued to her for tax year 2021. The motion also seeks to dismiss this case as to a notice of determination for tax year 2021 on the ground that no notice of determination was issued to petitioners for tax year 2021.
Upon due consideration, it is
ORDERED that, on or before July 31, 2024, respondent shall file a Supplement to his motion to dismiss and shall address whether the Court has jurisdiction as to tax year 2020.