Opinion
16382-22
01-23-2023
ANAHIT MKRTCHYAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On September 13, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not timely filed with respect to petitioner's 2019 tax year. However, respondent does not state whether the Court has jurisdiction with respect to petitioner's 2020 and 2021 tax years.
Upon due consideration, it is
ORDERED that, on or before February 10, 2023, respondent shall file a supplement to his motion to dismiss. In the supplement, respondent shall set forth and discuss fully respondent's position of whether the Court jurisdiction with respect to petitioner's 2020 and 2021 tax years.