Opinion
1312-16L
12-13-2021
Sheila Ann Smith Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
James S. Halpern Judge
On March 10, 2021, we issued our Memorandum Opinion in this case, Smith v. Commissioner, T.C. Memo. 2021-29. On June 13, 2021, petitioner filed a notice of appeal with the United States Court of Appeals for the Ninth Circuit. On June 22, 2021, petitioner filed a motion for reconsideration of findings or opinion pursuant to Rule 161, Tax Court Rules of Practice and Procedure (motion). By order entered June 24 2021, we ordered that the motion be held in abeyance pending the appeal. On December 6, 2021, we received the mandate of the Court of Appeals dismissing petitioner's appeal for lack of jurisdiction. There is, therefore, no reason not to proceed with our consideration of the motion. It is
ORDERED that, on or before, January 27, 2022, respondent shall file with the Court and serve on petitioner a written response to the motion.