Lawton v. Comm'r of Internal Revenue

Full title: DIAMOND LAWTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Oct 17, 2023

No. 11408-23 (U.S.T.C. Oct. 17, 2023)

Opinion

11408-23

10-17-2023

DIAMOND LAWTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan Chief Judge

ORDER

Kathleen Kerrigan Chief Judge

On September 6, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency had been sent to petitioner with respect to tax year 2020, nor had respondent made any other determination with respect to petitioner's 2020 tax year that would confer jurisdiction on this Court.

On October 13, 2023, respondent filed a First Supplement to Motion to Dismiss for Lack of Jurisdiction. Therein respondent stated that petitioner had, in fact, been issued a notice of deficiency for tax year 2020. Respondent accordingly asked the Court to deny the earlier motion.

Upon due consideration and for cause, it is

ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented, is denied. It is further

ORDERED that respondent shall, on or before December 15, 2023, file an Answer in this case.