Opinion
7377-21
03-08-2022
Phyllis D. Mabbett Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Albert G. Lauber Judge
On March 7, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Respondent argues that no statutory notice of deficiency, as authorized by I.R.C. § 6212 and required by I.R.C. § 6213(a) to form the basis for a petition to this Court, has been sent to petitioner with respect to the 2008 tax year. Respondent further contends that the IRS has made no other determination with respect to that year that would confer jurisdiction on this Court. Upon due consideration, it is
ORDERED that petitioner shall file, on or before April 8, 2022, a response to the Motion to Dismiss for Lack of Jurisdiction and attach thereto a copy of the IRS determination that she contends gives the Court jurisdiction over this case. If petitioner does not respond, the Court will likely grant respondent's Motion to Dismiss.