Opinion
4060-24
04-15-2024
VALERIE SAULINO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
Upon due consideration of the Motion To Dismiss for Lack of Jurisdiction, filed April 11, 2024, by respondent in the above-docketed matter, wherein respondent seeks dismissal on the ground that the purported notice of deficiency for the taxable year 2021 is invalid, it is
ORDERED that, on or before May 3, 2024, petitioner shall file an objection, if any, to respondent's just-referenced motion. Failure to comply with this Order may result in the granting of respondent's motion and dismissal of the instant case or other appropriate action by this Court. The Court would note that if petitioner wishes to seek a refund of amounts paid, an appropriate procedure would be to submit a claim for refund to the Internal Revenue Service (IRS), with any subsequent litigation handled by the U.S. District Court or U.S. Court of Federal Claims.