Opinion
11442-22S
01-12-2023
GARY B. REYNOLDS & KERRI A. REYNOLDS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On August 22, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Petitioner Kerri A. Reynolds, and to Change Caption on the ground that respondent has not issued a notice of deficiency for tax year 2018 to petitioner Kerri A. Reynolds. However, respondent does not state whether he issued a notice of deficiency for tax year 2019 to petitioner Kerri A. Reynolds.
Upon due consideration, it is
ORDERED that, on or before February 2, 2023, respondent shall file a Supplement to his motion to dismiss. In the supplement, respondent shall set forth and discuss fully respondent's position of whether he issued a notice of deficiency for tax year 2019 to petitioner Kerri A. Reynolds.