Opinion
28460-21S
03-10-2022
Brenda Ann Kyle & Kevin P. Kyle Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
Pending in the above-docketed matter is a Motion to Dismiss for Lack of Jurisdiction as to Petitioners Dispute Regarding Notice of Determination Concerning Collection Action, filed February 22, 2022, by respondent. However, on March 3, 2022, respondent filed a status report advising that such motion failed to address the jurisdictional status of this case in a comprehensive matter.
Accordingly, for purposes of ensuring clarity of the record, it is
ORDERED that the Motion to Dismiss for Lack of Jurisdiction as to Petitioners' Dispute Regarding Notice of Determination Concerning Collection Action filed February 22, 2022, is denied. It is further
ORDERED that, on or before March 30, 2022, respondent shall file a proper jurisdictional motion addressing all bases relevant to the Court's jurisdiction herein. 1