Opinion
13127-22S
08-30-2023
LEVANUS FELIX SAWYER, DECEASED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On June 10, 2022, petitioner filed the petition in this case. On August 1, 2022, respondent filed the Answer. By Order served April 20, 2023, the Court directed respondent to either file an appropriate jurisdictional motion or a report addressing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation on or before May 12, 2023. Instead, on July 6, 2023, respondent filed a Status Report that does not address the basis or bases for the Court's jurisdiction or have any supporting documentation attached.
By Order served July 19, 2022, the Court again directed respondent to either file an appropriate jurisdictional motion or a report addressing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation on or before August 9, 2023. On August 9, 2023, respondent filed two status reports addressing Shamari Sawyer's capacity to represent petitioner, but respondent did not address the basis or bases for the Court's jurisdiction or have any supporting documentation attached.
Upon due consideration, it is
ORDERED that, on or before September 20, 2023, respondent shall file either: (1) an appropriate jurisdictional motion or (2) a report addressing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation. It is further
ORDERED that, on or before September 20, 2023, respondent shall file a status report with the Court concerning the then-present status of this case, including respondent's position as to whether, under Georgia law, Shamari Sawyer has the capacity to represent decedent before this Court.