Opinion
27575-22
03-11-2024
KAREN LEE SHUSTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 19, 2022, petitioner filed the Petition to commence this case, seeking review of a notice of deficiency issued for her 2019 tax year. On March 5, 2023, petitioner filed a Letter Dated February 27, 2024, in which she states that she wishes "to protest yet another unlawful IRS collection notice, which it sent to me last month." Petitioner's letter suggests that such collection notice pertained to her 2018 and/or 2019 tax years.
Upon due consideration, it is
ORDERED that petitioner's above-referenced letter is recharacterized as a Motion to Restrain Assessment or Collection or to Order Refund of Amount Collected. It is further
ORDERED that, on or before April 1, 2024, petitioner shall file a supplement to her Motion to Restrain Assessment or Collection or to Order Refund of Amount Collected and thereto attach a copy of the collection notice that she references in the Motion.