Opinion
12680-23S
03-20-2024
GASPARD PIERRE LOUIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
The petition in the above-docketed matter was filed on August 7, 2023, and 2021 was indicated as the taxable year in dispute. An answer to the petition followed on September 27, 2023, attaching a notice of deficiency dated March 20, 2023, issued to petitioner with respect to the 2021 taxable year. The answer further asserted that the petition was rendered timely by disaster relief under FEMA-4709-DR-FL.
Thereafter, the parties on March 18, 2024, submitted a Proposed Stipulated Decision resolving the case. Nonetheless, additional review of the record has raised questions concerning the aforementioned disaster relief. To wit, Internal Revenue Service Notices FL-2023-04 (May 1, 2023) and IR-2023-94 (May 2, 2023) appear to limit the relief described therein solely to Broward County, Florida. Conversely, petitioner's address of record is Miami, in Miami-Dade County. (Notably, the petition also mentions military deployment in South Korea, which could also impact the timeliness aspect of the case, although specifics thereof have not been presented to date.)
Accordingly, to clarify the record herein prior to taking action with respect to the Proposed Stipulated Decision, it is
ORDERED that, on or before April 10, 2024, respondent shall file a report and shall address therein the timeliness considerations referenced above.