Opinion
18560-21
03-07-2023
JENNIFER SIMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On May 26, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on October 4, 2021, by respondent's answer thereto. However, upon further review, it came to the Court's attention that although the pleadings might reference the notice or notices of deficiency or determination upon which this litigation was based, no complete copy of such notice(s) had been provided. It was therefore advisable to ensure that the record herein was complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods, and respondent was directed to file appropriate materials.
Subsequently, on March 6, 2023, respondent filed an initial response indicating that a jurisdictional motion would be forthcoming. Accordingly, upon due consideration, it is
ORDERED that, on or before April 3, 2023, respondent shall file either: (1) An appropriate jurisdictional motion; and/or (2) a report establishing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation.