Opinion
26465-22S
03-28-2023
JONATHAN GRIESE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On February 13, 2023, respondent, the Commissioner of Internal Revenue, filed a Motion to Dismiss for Lack of Jurisdiction. Respondent asserts in his motion that, as to petitioner's 2012 tax year (1) no notice of determination concerning relief from joint and several liability under Internal Revenue Code section 6015 has been issued to petitioner, (2) respondent has not failed to make a determination under section 6015 within 6 months of an election or claim for relief, (3) nor has respondent made any other determination sufficient to confer jurisdiction on this Court.
Upon due consideration, it is
ORDERED that, on or before April 19, 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 of this case for lack of jurisdiction.
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