Opinion
16709-21S
02-02-2023
JEFFREY PATTERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
By Order and Order of Dismissal for Lack of Jurisdiction (Order), entered December 30, 2022, this case was dismissed for lack of jurisdiction on the grounds that the petition was not filed within the time prescribed in the Internal Revenue Code. On January 30, 2023, petitioner filed a Letter Dated January 19, 2023, suggesting that the Court's Order dismissing this case was based upon an inadvertent clerical error and requesting that the Court vacate its Order.
Upon due consideration and for cause, it is
ORDERED that petitioner's Letter Dated January 19, 2023, is recharacterized as a Motion to Vacate or Revise Pursuant to Rule 162. It is further
ORDERED that petitioner's Motion to Vacate or Revise Pursuant to Rule 162 is granted and the Court's Order and Order of Dismissal for Lack of Jurisdiction, entered December 30, 2022, is vacated and set aside. It is further
ORDERED that the Court's Order to Show Cause, issued May 20, 2022, is discharged. It is further
ORDERED that, on or before March 3, 2023, the parties shall file for the Court's consideration a proposed stipulated decision in order that this case may be concluded.