Opinion
4295-24
08-09-2024
RUSSELL J. KAAS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 9, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction (Docket Index No. 9), asserting therein that so much of this case relating to petitioner's 2019 tax year should be dismissed on the grounds that no notice of deficiency was issued, nor has respondent made any other determination, that would permit petitioner to invoke the jurisdiction of this Court as to petitioner's 2019 tax year.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction (Docket Index No. 9) is recharacterized as a Motion to Dismiss for Lack of Jurisdiction as to Tax Year 2019. It is further
ORDERED that, on or before September 3, 2024, petitioner shall file an Objection, if any, to respondent's above-referenced Motion. Failure to file a timely objection may result in the granting of the motion. The Court will take appropriate action after the period for timely objection.