Opinion
659-23
03-21-2023
MARCO B. LARSEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On January 26, 2023, petitioner filed the petition to commence this case, indicating therein that he seeks review of a notice of deficiency issued for his 2013, 2014, 2015, 2016, 2017, and 2018 tax years. On March 17, 2023, respondent filed an Answer to the petition. Attached to the Answer is a notice of determination concerning collection action issued as to petitioner's 2015, 2016, and 2017 tax years, which respondent asserts is the notice and the tax years properly at issue in this case. Also on March 17, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction and To Strike as to Tax Years 2013, 2014, and 2018.
ORDERED that the caption of this case is amended by adding the letter "L" to the docket number and this case shall be processed to trial or other disposition according to the Lien and Levy Action Procedures provided by Rules 330 et seq., Tax Court Rules of Practice and Procedure. It is further
ORDERED that, on or before April 11, 2023, petitioner shall file an Objection, if any, to respondent's above-referenced motion. Failure to file an objection may result in the granting of the motion.