Opinion
12683-20L
03-01-2022
SCOTT NICHOLAS SHADDIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
Pursuant to the Court's Opinion (T.C. Memo. 2022-11) issued in the above-docketed case on February 28, 2022, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction as to 2012 and 2017, filed July 23, 2021, is granted in that so much of this case as relates to tax years 2012 and 2017 is dismissed for lack of jurisdiction. It is further
ORDERED that respondent's Motion for Summary Judgment, filed August 5, 2021, is denied. It is further
ORDERED that respondent shall offer petitioner a supplemental administrative hearing at a reasonable and mutually agreeable date and time, but no later than May 31, 2022. It is further
ORDERED that respondent shall file with the Court, on or before June 30, 2022, a status report detailing the then-present status of the case. It is further
ORDERED that, if and when any supplemental notice of determination is issued to petitioner, respondent at that time shall file a status report and attach thereto a copy of the supplemental notice of determination.