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Sherman v. Comm'r of Internal Revenue

United States Tax Court
Nov 16, 2022
No. 11951-20L (U.S.T.C. Nov. 16, 2022)

Opinion

11951-20L

11-16-2022

DAVID SHERMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

David Gustafson, Judge

On November 7, 2022, the Commissioner filed a motion for partial summary judgment (Doc. 23) and a motion to dismiss (Doc. 24). It is

ORDERED that, no later than December 16, 2022, petitioner David Sherman shall file a response to each of the two motions. If the Commissioner's motions make allegations that Mr. Sherman believes to be incorrect, then his responses should identify the errors and support his corrections. In addition to anything else he might wish to state in his responses, he should consider demonstrating

(1) whether there is any reason or circumstance that might excuse or justify his mailing his petition on September 18, 2020, rather than on or before September 17, 2020, and
(2) whether the IRS issued to him any notice of deficiency (as opposed to the "Notice Determination" dated August 18, 2020 (Doc. 23, Ex. A)) that might give this Court jurisdiction to redetermine a deficiency for any year.

It is further

ORDERED that, no later than January 13, 2023, the Commissioner shall file a reply to each of Mr. Sherman's responses (or, if Mr. Sherman has filed no responses, then a status report so stating).


Summaries of

Sherman v. Comm'r of Internal Revenue

United States Tax Court
Nov 16, 2022
No. 11951-20L (U.S.T.C. Nov. 16, 2022)
Case details for

Sherman v. Comm'r of Internal Revenue

Case Details

Full title:DAVID SHERMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court:United States Tax Court

Date published: Nov 16, 2022

Citations

No. 11951-20L (U.S.T.C. Nov. 16, 2022)