Opinion
29678-21
01-11-2023
SURESH D. SIVASITHAMPARAM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Upon due consideration of the Motion to Dismiss for Lack of Jurisdiction, filed December 14, 2021, and the attachments thereto which do not establish that a notice of deficiency was issued to petitioner on May 9, 2018, it is
ORDERED that respondent's motion is denied, without prejudice.