Merchia v. Comm'r of Internal Revenue

Full title: PANKAJ MERCHIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Sep 24, 2024

No. 7467-24 (U.S.T.C. Sep. 24, 2024)

Opinion

7467-24

09-24-2024

PANKAJ MERCHIA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

KATHLEEN KERRIGAN CHIEF JUDGE

ORDER

KATHLEEN KERRIGAN CHIEF JUDGE

On May 10, 2024, petitioner filed the petition in this case seeking review of a purported notice of deficiency issued for tax years 2008 through 2023.On June 17, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no statutory notice of deficiency has been sent to petitioner and respondent has not made any other determination that would confer jurisdiction on this Court. By Order served June 28, 2024, the Court directed petitioner to file an objection to respondent's motion, if any, on or before July 22, 2024. Petitioner failed to file an objection to respondent's motion by July 22, 2024.

On July 18, 2024, petitioner filed a Motion for Extension of Time, requesting 180 days to file an objection. By Order served July 19, 2024, the Court granted petitioner's motion and directed petitioner to file an objection to respondent's motion, if any, on or before August 19, 2024. Petitioner failed to file an objection to respondent's motion by August 19, 2024.

On August 19, 2024, petitioner filed a second Motion for Extension of Time, seeking an additional 30 days to file an objection. By Order served August 23, 2024, the Court extended the time to file an extension to September 23, 2024. Petitioner failed to file an objection to respondent's motion by September 23, 2024.

On September 23, 2024, petitioner filed a third Motion for Extension of Time, seeking an additional week to file an objection to respondent's motion.

Upon due consideration, it is

ORDERED that petitioner's above-referenced motion is granted in that the time within which petitioner shall file an Objection to respondent's Motion to Dismiss for Lack of Jurisdiction is extended to September 30, 2024.Failure to file an objection to respondent's Motion to Dismiss for Lack of Jurisdiction by September 30, 2024, may result in granting of respondent's motion and dismissal of this case or other appropriate action by this Court.