Opinion
1138-24
08-06-2024
DONALD PERRY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On March 8, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction. By Order of Dismissal for Lack of Jurisdiction entered July 1, 2024, the Court granted respondent's motion and dismissed this case for lack of jurisdiction.
On August 1, 2024, petitioner filed a Motion for Reconsideration of Order. Although petitioner asserts therein that he was prevented from mailing his objection to respondent's Motion to Dismiss for Lack of Jurisdiction, consideration of petitioner's objection, as attached to his Motion for Reconsideration of Order, would have made no difference in the outcome of this matter. Petitioner still has not produced or otherwise demonstrated that he was issued any notice of deficiency, notice of determination concerning collection action, notice of determination concerning relief from joint and several liability, notice of final determination for disallowance of interest abatement claim, or notice of certification of your seriously delinquent federal tax debt to the Department of State, or that respondent has made or failed to make any other determination, as to his 2019, 2020, 2021, and 2022 tax years that would permit him to invoke the jurisdiction of this Court.
Upon due consideration of the foregoing, it is
ORDERED that petitioner's Motion for Reconsideration of Order is denied.