Opinion
16369-22
09-19-2022
JIMMIE L. MAGEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On July 11, 2022, petitioner filed an imperfect petition to commence this case which consisted of a partial copy of a notice of deficiency issued for petitioner's 2021 tax year. On August 8, 2022, petitioner filed a First Amended Petition in which petitioner indicates that he seeks review of a notice of deficiency issued for his 2022 tax year.
On September 14, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Year 2022 and to Strike. Respondent asserts in his motion that no notice of deficiency or notice of determination sufficient to confer jurisdiction on this Court has been issued to petitioner for the 2022 tax year.
Upon due consideration, it is
ORDERED that, on or before October 11, 2022, petitioner shall file an Objection, if any, to respondent's above-referenced motion. Failure to file an 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 year 2022. Petitioner is advised that respondent's motion does not seek dismissal of so much of this case relating to petitioner's 2021 tax year.