Rynes v. Comm'r of Internal Revenue

Full title: JILLIANNE RYNES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Jul 25, 2024

No. 9476-24 (U.S.T.C. Jul. 25, 2024)

Opinion

9476-24

07-25-2024

JILLIANNE RYNES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan Chief Judge

ORDER

Kathleen Kerrigan Chief Judge

On July 23, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction. However, review of that Motion shows that respondent seeks to dismiss this case for lack of jurisdiction only in part, namely, with respect to a notice of determination concerning collection action. The Motion does not address this Court's jurisdiction with respect to the notice of deficiency attached to the Petition, which was issued to petitioner for tax year 2021.

It is accordingly

ORDERED that respondent's above-referenced Motion is recharacterized as respondent's Motion to Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Collection Action. It is further

ORDERED that, on or before August 15, 2024, petitioner shall file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Collection Action. Failure to file a timely objection may result in the granting of that Motion.