Opinion
12860-22S
08-03-2022
DAVID WILLIAM PROCTOR & CYNTHIA LYNN PROCTOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 8, 2022, the Court received from petitioner in the above-docketed matter a letter requesting that the instant proceeding be closed. In support of such request, petitioners advised that the underlying 2018 taxes had been resolved with the Internal Revenue Service (IRS) through payment. Review of the record herein, however, suggests that the basis for any closure of the case may be different as to the two petitioners, insofar as jurisdictional questions are raised with respect to petitioner Cynthia Lynn Proctor.
Accordingly, to clarify and to ensure appropriate treatment as to each petitioner, it is
ORDERED that, on or before August 23, 2022, respondent shall file either: (1) An appropriate jurisdictional motion as to Cynthia Lynn Proctor; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Cynthia Lynn Proctor and attaching thereto a copy of any supporting documentation.