Minieri v. Comm'r of Internal Revenue

Full title: MICHAEL WILLIAM MINIERI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court: United States Tax Court

Date published: Aug 1, 2023

No. 7981-23S (U.S.T.C. Aug. 1, 2023)

Opinion

7981-23S

08-01-2023

MICHAEL WILLIAM MINIERI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan, Chief Judge

ORDER

Kathleen Kerrigan, Chief Judge

Pending before the Court is respondent's Motion to Dismiss for Lack of Jurisdiction, filed July 21, 2023. On July 24, 2023, petitioner electronically filed (1) a Notice of Objection to Motion to Dismiss for Lack of Jurisdiction and (2) a First Amendment to Notice of Objection to Motion to Dismiss for Lack of Jurisdiction. Thereafter, on July 27, 2023, petitioner electronically filed an Administrative Record.

In consideration of the foregoing, it is

ORDERED that petitioner's Notice of Objection to Motion to Dismiss for Lack of Jurisdiction is recharacterized as petitioner's Objection to Motion to Dismiss for Lack of Jurisdiction. It is further

ORDERED that petitioner's First Amendment to Notice of Objection to Motion to Dismiss for Lack of Jurisdiction is recharacterized as petitioner's First Supplement to Objection to Motion to Dismiss for Lack of Jurisdiction. It is further

ORDERED that petitioner's Administrative Record is recharacterized as petitioner's Second Supplement to Objection to Motion to Dismiss for Lack of Jurisdiction. It is further

ORDERED that, on or before August 23, 2023, respondent shall file a response to petitioner's Objection to Motion to Dismiss for Lack of Jurisdiction, as supplemented.