Opinion
7049-24
06-26-2024
NASEEM SENAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 4, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the Petition was not filed within the time prescribed in the Internal Revenue Code. On June 25, 2024, the Court received from petitioner and filed a Letter Dated June 10, 2024, in which petitioner states his objection to the respondent's motion to dismiss. Specifically, petitioner states:" It is pertinent to note that the IRS failed to notify me of any outstanding issues or liabilities owed, as they inaccurately sent correspondence to an address where I did not reside. I had provided evidence of my correct address, yet notifications were consistently sent to the address my ex-spouse had posted to prevent my awareness."
Upon due consideration of the foregoing, it is
ORDERED that petitioner's Letter Dated June 10, 2024, is recharacterized as an Objection to Motion to Dismiss for Lack of Jurisdiction. It is further
ORDERED that, on or before July 18, 2024, petitioner shall file a supplement to the Objection to Motion to Dismiss for Lack of Jurisdiction and therein provide the following information: (1) petitioner's correct address as of April 3, 2023, and (2) what steps (and on what dates those steps were taken) that petitioner to took to inform the IRS of petitioner's correct address prior to April 3, 2023. Petitioner shall attach to petitioner's supplement all documentation on which petitioner relies to establish that petitioner informed the IRS of petitioner's correct address prior to April 3, 2023.