Opinion
20296-21
10-03-2023
CHAELES BERNARD POWELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
L. Paige Marvel Judge
On September 29, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Respondent asserts in his motion that no notice of deficiency was issued to petitioner as to tax years 2000-2002 and 2004-2020, and that petitioner failed to timely petition the Court in response to the notice of deficiency issued to petitioner for tax year 2003. Respondent also asserts in his motion that no notice of determination was issued to petitioner as to tax years 2000-2002 and 2006-2020, and that petitioner failed to timely petition the Court in response to the notice of determination issued to petitioner for tax years 2003-2005.
Upon due consideration, it is
ORDERED that, on or before October 24, 2023, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.