Opinion
37377-21
01-25-2023
MIGUEL A. TORRES SALAS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On March 29, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. On May 25, 2022, petitioner filed a Notice of Objection to Motion to Dismiss for Lack of Jurisdiction, but failed to address the USPS tracking attached to respondent's motion or provide a postmarked certified mail receipt.
Upon due consideration, it is
ORDERED that, on or before February 15, 2023, petitioner shall file a Supplement to his objection, in which he shall address the USPS tracking attached to respondent's motion. Petitioner shall attach to his supplement a copy of any postmarked certified mail receipt postmarked by the postal employee to whom petitioner presented the petition when petitioner mailed the petition to the Court.