Opinion
17285-23
03-01-2024
KAMINI RANGAPPAN LANE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On February 29, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that, as to a notice of deficiency issued for petitioner's 2021 tax year, the Petition to commence this case was not filed within the time prescribed in the Internal Revenue Code. (Respondent previously filed a Motion to Dismiss for Lack of Jurisdiction on December 21, 2023, relating to petitioner's 2023 tax year, and a First Supplement to Motion to Dismiss for Lack of Jurisdiction on February 26, 2024, relating to petitioner's 2022 tax year.) With respect to the notice of deficiency issued for petitioner's 2021 tax year, further review has raised questions regarding the potential applicability of any disaster relief afforded to Los Angeles County, California residents.
Upon due consideration of the foregoing, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed February 29, 2024, is recharacterized as a Second Supplement to Motion to Dismiss for Lack of Jurisdiction. It is further
ORDERED that, on or before March 22, 2024, respondent shall file a third supplement to his Motion to Dismiss for Lack of Jurisdiction clarifying the relevance, if any, of disaster relief in this case as to the notice of deficiency issued for petitioner's 2021 tax year.