Opinion
15668-23S
11-27-2023
SE HO LEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On November 20, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Therein respondent moves that this case be dismissed for lack of jurisdiction on the ground that no notice of deficiency, as challenged in the Petition, was sent to petitioner with respect to tax years 2021 and 2022, nor has respondent made any other determination with respect to petitioner's 2021 and 2022 tax years that would confer jurisdiction on this Court.
Upon due consideration, it is
ORDERED that, on or before December 18, 2023, petitioner shall file an Objection, if any, to the above-described motion. Failure to comply with this Order may result in the granting of the motion or other action as the Court deems appropriate.