Opinion
7035-23S
06-13-2023
INSTALLATION SERVICE GROUP, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On May 5, 2023, petitioner filed the petition to commence this case, seeking review of a purported notice of deficiency issued for taxable periods ending 2/2015, 3/2017, 6/2018, and 12/2018.
On June 9, 2023, respondent filed his Answer to the petition and a Motion to Change or Correct Caption. In his Answer, respondent alleges that the notice properly at issue in this case is a notice of determination concerning collection action, dated April 26, 2023, issued for petitioner's taxable periods ending 6/2015, 3/2017, 6/2018, and 12/2018. In his motion, respondent asks that a lien or levy designation be added in this case.
Upon due consideration, it is
ORDERED that respondent's Motion to Change or Correct Caption is recharacterized as a Motion to Add Lien or Levy Designation. It is further
ORDERED that respondent's Motion to Add Lien or Levy Designation is granted in that the caption of this case is amended by adding the letter "L" to the docket number and the Clerk of the Court shall process this case to trial or other disposition according to the Lien and Levy Action Procedures provided by Rules 330 et seq., Tax Court Rules of Practice and Procedure. It is further
ORDERED that, on or before July 5, 2023, respondent shall file an appropriate jurisdictional motion with respect to so much of this case relating to a notice of deficiency and the taxable period ending 2/2015.