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Schouest v. Comm'r of Internal Revenue

United States Tax Court
Dec 27, 2023
No. 14859-23L (U.S.T.C. Dec. 27, 2023)

Opinion

14859-23L

12-27-2023

CLINTON P. SCHOUEST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan, Chief Judge

On December 21, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to the Taxable Years 2011, 2012, 2013, 2014, 2015, 2016, 2018, and 2019 and To Strike. Respondent asserts in his motion that no notice of deficiency or notice of determination concerning collection action sufficient to confer jurisdiction on this Court as to petitioner's 2011, 2012, 2013, 2014, 2015, 2016, 2018, and 2019 tax years was issued to petitioner.

Upon due consideration, it is

ORDERED that, on or before January 19, 2024, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to petitioner's 2011, 2012, 2013, 2014, 2015, 2016, 2018, and 2019 tax years. Petitioner is advised that respondent's motion does not seek dismissal of so much of this case relating to the notice of determination concerning collection action issued for petitioner's 2017 tax year.


Summaries of

Schouest v. Comm'r of Internal Revenue

United States Tax Court
Dec 27, 2023
No. 14859-23L (U.S.T.C. Dec. 27, 2023)
Case details for

Schouest v. Comm'r of Internal Revenue

Case Details

Full title:CLINTON P. SCHOUEST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Dec 27, 2023

Citations

No. 14859-23L (U.S.T.C. Dec. 27, 2023)