Opinion
26330-22
02-07-2023
DANIYAL HASSAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
The petition in the above-docketed matter was filed on November 28, 2022, and 2019 was reflected as the taxable year in dispute. Attached to the petition was a notice of deficiency dated September 6, 2022, issued to petitioner with respect to the 2019 taxable year. An answer to the petition followed on February 6, 2023, likewise attaching a notice of deficiency issued to petitioner for the 2019 tax year. However, that notice was dated August 15, 2022, and the answer was inexplicably silent as to the discrepancy and related jurisdictional matters.
Accordingly, the premises considered, it is
ORDERED that, on or before March 7, 2023, respondent shall file a report addressing the discrepancy between the two purported notices of deficiency and advising as to jurisdictional implications thereof.