Opinion
18162-21
04-01-2022
PAUL JAROSIK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge.
On December 7, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that the petition was not timely filed as to the notice of deficiency issued for tax year 2018. In the motion, respondent notes that the notice of deficiency was mailed to petitioner on February 16, 2021. However, PS Form 3877 attached to respondent's motion appears to indicate that the notice of deficiency was mailed to petitioner on February 18, 2021.
Upon due consideration, it is
ORDERED that, on or before April 22, 2022, respondent shall file a Supplement to his motion and clarify the date that the notice of deficiency was mailed to petitioner.
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