Opinion
12519-23
11-29-2023
SOULEYMANE KARAMOKO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On August 8, 2023, petitioner filed the Petition to commence this case, indicating that petitioner seeks review of a notice of deficiency and a notice of determination concerning collection action issued for petitioner's 2020 tax year. On November 22, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. As grounds for his motion, respondent asserts that so much of this case relating to a notice of determination concerning collection action for petitioner's 2020 tax year should be dismissed for lack of jurisdiction because no such notice has been issued to petitioner that would confer jurisdiction on this Court.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is recharacterized as a Motion to Dismiss for Lack of Jurisdiction as to a Notice of Determination Concerning Collection Action. It is further
ORDERED that, on or before December 22, 2023, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to a notice of determination concerning collection action. Petitioner is advised that respondent's motion does not seek dismissal of so much of this case relating to the notice of deficiency, dated May 22, 2023, issued for petitioner's 2020 tax year.