Opinion
2069-24
06-21-2024
KEVIN TRAMAINE MADISON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On February 5, 2024, petitioner Kevin Tramaine Madison filed the Petition to commence this case, indicating therein that he seeks review with respect to a notice of final determination of disallowance of interest abatement claim (or failure of IRS to make final determination within 180 days after claim for abatement) in connection with his 2022 and 2023 tax years. No notice deficiency or notice of determination is attached to the Petition nor does petitioner allege that he filed any interest abatement claim relating to his 2022 and 2023 tax years. On March 12, 2024, respondent filed an Answer to the Petition. Therein, respondent asserts that only a notice of deficiency issued for petitioner's 2021 tax year is properly at issue in this case. On June 20, 2024, the parties filed a Proposed Stipulated Decision that addresses only a deficiency for petitioner's 2021 tax year.
Upon due consideration of the foregoing, it is
ORDERED that, on or before July 12, 2024, respondent shall file an appropriate jurisdictional motion with respect to so much of this case relating to a notice of final determination of disallowance of interest abatement claim (or failure of IRS to make final determination within 180 days after claim for abatement) for petitioner's 2022 and 2023 tax years. We will hold the parties' Proposed Stipulated Decision pending further action by the Court.