Opinion
10525-24S
09-25-2024
TIMOTHY LORENZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On September 23, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction. As grounds for his motion, respondent asserts that so much of this case relating to tax years 2023 and 2024 should be dismissed because no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2023 and 2024 tax years.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is recharacterized as a Motion to Dismiss for Lack of Jurisdiction as to Tax Years 2023 and 2024. It is further
ORDERED that, on or before October 25, 2024, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file a timely objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to tax years 2023 and 2024. The Court will take appropriate action following the period for objection. Petitioner is advised that respondent's motion does not seek to dismiss this case insofar as it relates to the notice of deficiency issued for petitioner's 2021 tax year.
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