Opinion
23149-21L
02-28-2023
KEITH BARCLAY NELSON & CHRISTINE ALICIA KOURTIDES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson Judge
This is a "collection due process" case in which the petition seeks relief for five taxable years--i.e., 2013, 2014, 2016, 2017, and 2018. The case is set for trial at the Tax Court's Washington, D.C., trial session beginning May 8, 2023. The Commissioner has filed a motion (Doc. 19) to dismiss the petition in part as to two of those years--i.e., 2013 and 2014. The motion explains that the Tax Court does not have jurisdiction over those two years. If we grant the motion, the other three years (2016, 2017, and 2018) would not be dismissed but would remain at issue. It is
ORDERED that, no later than March 17, 2023, petitioners Keith Barclay Nelson and Christine Alicia Kourtides shall file with the Court and serve on the Commissioner a response to the motion to dismiss 2013 and 2014. If they object to the motion, then their response shall state the reasons for their objection. It is further
ORDERED that, no later than March 31, 2023, the Commissioner shall file a reply to the petitioners' response (or, if they have filed no response, then he shall file a status report so stating).