Opinion
13042-21
04-21-2023
RAMON A. RODRIGUEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge
On June 30, 2021, petitioner in this matter petitioned this Court with respect to tax year ending December 31, 2017. However, the petition did not include a Notice of Deficiency with respect to tax year 2017 which is in dispute in this matter.
By Order served on April 20, 2022, this Court ordered respondent to file a copy of respondent's Notice of Deficiency, issued to petitioner upon which this case is based. On May 5, 2022, respondent filed a copy of a Notice of Deficiency and Penalty Approval Form upon which this case is based; however, the Notice of Deficiency was an undated copy. Nor did respondent's filings include a copy of PS Form 3877 which would show the date of the mailing of the notice of the deficiency and/or a copy of Form 9984 which contains the examining officer's activity report and documents the actions taken during the audit. Therefore, the Court is unable to confirm whether it has jurisdiction over this matter.
Considering the foregoing, it is
ORDERED that on or before May 15, 2023, respondent is to supplement its May 5, 2022 filing, to include additional evidence (including but not limited to Forms 3877 and 9984) confirming this Court's jurisdiction in this matter.