Opinion
5567-22S
10-03-2022
CHRISTIAN ORTEGA & JHOANA MOROCHO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On April 20, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Respondent captioned the motion solely in the name of petitioner Christian Ortega. In the motion, respondent states that no statutory notice of deficiency was issued to petitioner for tax year 2019 and petitioner timely filed her petition for tax year 2019. Respondent also states that petitioner attached to the petition a notice of deficiency for tax year 2017. No notice of deficiency was attached to either the petition or respondent's motion. No certificate of service was attached to respondent's motion for petitioner Jhoana Morocho.
Upon due consideration, it is
ORDERED that, on or before October 24, 2022, respondent shall file either a Supplement to his motion or an amended motion.