Opinion
16564-23
02-07-2024
ANA G. PADILLA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On February 7, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of deficiency, nor any other determination sufficient to confer jurisdiction on this Court in this case, has been issued to petitioner. However, the Motion does not appear to account for petitioner's filing of the First Amended Petition on December 14, 2023, insofar as the Motion claims that petitioner "did not complete a form petition." Moreover, the Motion does not respond specifically to petitioner's allegations in the First Amended Petition as to the IRS actions that petitioner disputes. It is accordingly
ORDERED that, on or before March 1, 2024, respondent shall file a supplement to his above-referenced Motion and shall therein respond specifically to petitioners' allegations in the First Amended Petition.