Opinion
18439-22
10-18-2022
SPENCER CHRISTIAN LONG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On August 19, 2022, petitioner filed the petition to commence this case, indicating on the petition form that petitioner seeks review with respect to a notice of deficiency issued July 18, 2022, for the 2022 tax year. Petitioner did not attach to the petition a copy of the notice of deficiency. On October 14, 2022, respondent filed a Response to the Court's Order served September 29, 2022, and attached a copy of a notice of deficiency issued July 18, 2022, petitioner's 2019 tax year. Thus it appears that this Court lacks jurisdiction as to petitioner's 2022 tax year.
Upon due consideration of the foregoing, it is
ORDERED that, on or before November 8, 2022, respondent shall file an appropriate jurisdictional motion with respect to so much of this case relating to petitioner's 2022 tax year.