Opinion
732-21
08-01-2024
JEFFREY S. PITTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge
Respondent filed a Motion to Dismiss for Lack of Jurisdiction (Motion to Dismiss) in this case on March 30, 2021, and petitioner filed an Objection to respondent's Motion to Dismiss on May 24, 2021. On July 1, 2021, respondent filed a Response to petitioner's Objection to respondent's Motion to Dismiss. The undersigned was assigned this case on April 17, 2024.
In Abdo v. Commissioner, No. 5514-20, 162 T.C. (April 2, 2024), we concluded that the language in section 7508A(d)(1) provides for an automatic and mandatory postponement period that incorporates all of the acts referenced by section 7508A(a), including the filing of a Tax Court petition for the redetermination of a deficiency. To date, neither party has filed a supplemental pleading addressing this Court's decision in Abdo.
Considering the foregoing, it is
ORDERED that on or before September 6, 2024, the parties are permitted (if they so choose) to file a supplement, in support of or in opposition to respondent's Motion to Dismiss for Lack of Jurisdiction.