Opinion
7506-24
06-21-2024
PANKAJ MERCHIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 12, 2024, the Petition was filed in the above-docketed case. Therein petitioner indicated that he was challenging a notice of deficiency, issued February 12, 2024, for tax years 2008 through 2023. Petitioner further stated that this case was brought to have the Court enforce prior "agreements and judgments," evidently including stipulated decisions entered in the cases at Docket Nos. 9661-16 and 25665-17. The case at Docket No. 25665-17 was brought by a different petitioner. The case at Docket No. 9661-16 involved a notice of deficiency issued to petitioner for tax years 2009, 2010, and 2011.
On June 17, 2024, petitioner filed a Letter. Therein petitioner asserts that certain spreadsheets showing calculations of petitioner's tax liabilities for various tax years constitute a notice of deficiency for the tax years disputed in the Petition. According to petitioner, these spreadsheets were sent to petitioner's counsel in response to a discovery request in petitioner's criminal case.
It thus appears that petitioner's Letter constitutes a First Amendment to Petition.
Upon due consideration of the above, it is
ORDERED that petitioner's Letter, filed June 17, 2024, is recharacterized as a First Amendment to Petition. It is further
ORDERED that, on or before August 20, 2024, respondent shall either file an Answer or move with respect to the Petition, as amended.