Opinion
3939-24
05-09-2024
YAMILIN YORDI GUZMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On May 3, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Notice of Determination (2022). As grounds for his motion, respondent asserts that so much of this case relating to a notice of determination concerning collection action should be dismissed because no such notice sufficient to confer jurisdiction on this Court as to petitioner's 2022 tax year was issued to petitioner. Petitioner is advised that respondent's motion does not seek dismissal of petitioner's claims concerning the notice of deficiency issued for petitioner's 2022 tax year.
Upon due consideration of the foregoing, it is
ORDERED that, on or before May 31, 2024, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file a timely objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to a notice of determination concerning collection action. The Court will take appropriate action following the period for objection.