Opinion
13069-20S
03-17-2022
George M. Harris & Susan K. Harris Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On February 9, 2022, the Court issued an Order to Show Cause, directing the parties to show cause why this case should not be dismissed for lack of jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. In response, on March 4, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction in which, among other things, respondent asserts that the notice of deficiency for petitioners' 2017 tax year was sent to them by certified mail on February 10, 2022. Respondent, however, failed to attach to his motion a certified mail list or other proof of mailing to demonstrate that the notice of deficiency on which this case is based was properly mailed to petitioners on February 10, 2022.
Upon due consideration, it is
ORDERED that, on or before April 6, 2022, respondent shall file a supplement to his motion and attach thereto a certified mail list or other acceptable documentation in support of his assertion that the notice of deficiency on which this case is based was sent by certified mail to petitioners on February 10, 2022.