Opinion
24423-22S
11-22-2023
GINA ALANA RUSSO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Peter J. Panuthos Special Trial Judge.
By Notice served August 4, 2023, this case is calendared for trial at the December 11, 2023, Los Angeles, California, trial session of the Court. On October 27, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to taxable years 2017 and 2018. In his motion, respondent asserts that no statutory notices of determination concerning collection action were sent to petitioner for the taxable years 2017 and 2018. The Court will provide an opportunity for petitioner to respond.
Premises considered, it is
ORDERED that petitioner shall, on or before December 5, 2023, file a response to respondent's Motion to Dismiss for Dismiss for Lack of Jurisdiction, filed October 27, 2023. If petitioner objects to respondent's motion, any objection filed shall state with specificity the reason(s) for the objection.