Opinion
15647-24
11-05-2024
MARIA TERESA ESPINOZA IBARRA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 26, 2024, petitioner filed the Petition in this case seeking review of a notice of final determination for disallowance of interest abatement claim for tax year 2019. On October 16, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the Petition was not timely as to a notice of deficiency for tax year 2019.
Upon due consideration, it is
ORDERED that, on or before November 26, 2024, respondent shall file a supplement to his motion to dismiss and address whether petitioner filed a claim for abatement of interest.