Opinion
6544-24
07-10-2024
ERIC TANNER HOGAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Pending before the Court in this deficiency action is respondent's Motion to Dismiss for Lack of Jurisdiction, filed June 12, 2024. On July 8, 2024, petitioner filed an Objection thereto.
Upon due consideration of the foregoing, it is
ORDERED that, on or before August 1, 2024, respondent shall file a reply to petitioner's above-referenced Objection. Among other things, such reply shall state whether the mailing address to which the notices of deficiency in this case were sent by certified mail (as more fully described in respondent's Motion) was petitioner's last known address within the meaning of I.R.C. section 6212(b)(1).