Opinion
11307-24
09-03-2024
TROY REYNOLDS & MELINDA REYNOLDS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
The Petition to commence this case was filed on July 10, 2024. Therein petitioners indicated that they disputed a notice of deficiency and a notice of determination concerning collection action; attached to the Petition were copies of various IRS mailings and documents pertaining to tax year 2019.
On August 23, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the Petition was filed untimely as to the notice of deficiency issued to petitioners for tax year 2019. However, respondent does not address the Court's jurisdiction as to a notice of determination concerning collection action for tax year 2019.
In addition, further review of respondent's Motion shows that the copy of the notice of deficiency attached thereto has been excessively redacted, insofar as the redactions include petitioners' mailing address. That information is not listed as requiring redaction under Rule 27 of the Tax Court Rules of Practice and Procedure and, moreover, is necessary for the Court to determine whether the notice was sent to petitioners' last known address.
Upon due consideration and for cause, it is
ORDERED that, on or before September 24, 2024, respondent shall file a supplement to the above-referenced Motion. That supplement shall state whether petitioners were issued a notice of determination concerning collection action, or whether respondent made any other determination conferring jurisdiction on this Court, for tax year 2019. Respondent shall also attach to such supplement a properly redacted copy of the notice of deficiency for 2019.