Opinion
9409-24S
07-24-2024
ABDUL NAWABI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On June 6, 2024, petitioner filed the Petition to commence this case, indicating therein that petitioner seeks review of a notice of determination concerning collection action issued for petitioner's "2021/2022" tax years. On July 22, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that (1) as to a notice of deficiency issued for petitioner's 2021 tax year, the Petition was not filed within the time prescribed in the Internal Revenue Code, and (2) as to petitioner's 2022 tax year, respondent has issued no notice of deficiency or notice of determination sufficient to confer jurisdiction on this Court. Respondent's motion, however, does not address whether any notice of determination concerning collection action was issued for petitioner's 2021 tax year, as alleged in the Petition.
Upon due consideration of the foregoing, it is
ORDERED that, on or before August 14, 2024, respondent shall file a supplement to his above-described motion and therein address whether a notice of determination concerning collection action sufficient to confer jurisdiction on this Court as to petitioner's 2021 tax year was issued to petitioner.