Opinion
9100-24S
08-21-2024
ADAM SALEH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 22, 2024, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, in part on the ground that the petition herein was not filed within the time prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.). Respondent attached to the motion copies of a notice of deficiency and corresponding certified mail list, as evidence of the fact that such notice of deficiency for the taxable year 2020, dated January 3, 2023, had been sent to petitioner by certified mail on January 3, 2023. On August 19, 2024, the Court received from petitioner a document that appeared to be in the nature of and was filed as a response to the motion to dismiss. Therein, statements made by petitioner raised the question of whether the notice of deficiency was properly mailed to petitioner's last known address.
Upon due consideration, it is
ORDERED that, on or before September 11, 2024, respondent shall file a reply to petitioner's just-referenced response.