Opinion
3137-24
04-30-2024
JILL SCOTT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
The petition in this case was filed on February 26, 2024, seeking review of a notice of determination concerning relief from joint and several liability under section 6015 issued to petitioner on November 28, 2023, for tax year 2019. On April 19, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction seeking to dismiss tax year 2019 on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. In the motion, respondent asserts that a notice of deficiency was issued to petition for tax year 2019 on August 2, 2021.
Upon due consideration, it is
ORDERED that, on or before May 21, 2024, respondent shall file a Supplement to his motion to dismiss and shall address whether the Court has jurisdiction based on the November 28, 2023, notice attached to the petition.