Opinion
18111-23
01-10-2024
NICHOLAS VINH NGHIEM DUONG & JOCELYN RAGAMAT DUONG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On December 26, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction and to Strike as to the Taxable Years 2019, 2020, 2022, and 2023. Respondent moves that this case be dismissed, insofar as it concerns taxable years 2019, 2020, 2022, and 2023, on the grounds that no notice of deficiency has been issued to petitioners for those years, nor has respondent made any determination as to those years that would confer jurisdiction on the Court. However, respondent acknowledges that petitioners were issued a notice of deficiency for tax year 2021.
Upon due consideration, it is
ORDERED that, on or before January 31, 2024, petitioners shall file an objection, if any, to the above-described motion. Failure to comply with this Order may result in the granting of the motion and the dismissal of this case insofar as it concerns taxable years 2019, 2020, 2022, and 2023, or other action as the Court deems appropriate.