Opinion
15115-23S
12-22-2023
BLUDIZE ERICA SENATUS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 18, 2023, petitioner filed the Petition to commence this case, indicating that petitioner seeks review of a notice of deficiency and notice of determination concerning collection action issued for petitioner's 2023 tax year. No notice of deficiency or notice of determination is attached to the petition.
On December 13, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that, as to a notice of deficiency issued May 30, 2023, for petitioner's 2021 tax year, the Petition was not filed within the time prescribed in the Internal Revenue Code. However, respondent's motion fails to address petitioner's allegations with respect to a notice of determination concerning collection action and petitioner's 2023 tax year.
Upon due consideration of the foregoing, it is
ORDERED that, on or before January 16, 2024, respondent shall file a supplement to his above-referenced motion and therein address so much of this case relating to a notice of determination concerning collection action and petitioner's 2023 tax year.