Opinion
25078-21S
05-23-2023
ANDREW F. SAUCEDA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Lewis R. Carluzzo Chief Special Trial Judge
For cause, it is ORDERED that respondent's motion for leave, filed May 16, 2023, it granted. It is further
ORDERED that the Clerk of the Court file, as of the date lodged, respondent's motion to vacate. It is further
ORDERED that respondent's motion to vacate, filed May 16, 2023, is granted and the Decision entered and served on February 16, 2023, is vacated and set aside. It is further
ORDERED that respondent's motion to dismiss, filed May 17, 2023, is granted, and so much of this case as relates to 2017 is dismissed for lack of jurisdiction because the petition was not filed within the period prescribed by I.R.C. section 6213(a) with respect to that year.