Opinion
769-23
03-31-2023
FRANK E. STROUPE, SR. & RENITA T. STROUPE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On January 30, 2023, petitioners filed the petition to commence this case, indicating therein that they seek review of a notice of deficiency issued for their 2022 tax year. Attached to the petition, however, is a notice of deficiency issued for petitioners' 2020 tax year.
On March 13, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2022 and To Strike. Respondent asserts in his motion that no notice of deficiency has been issued to petitioners, nor has respondent made any other determination, with respect to petitioners' 2022 tax year sufficient to confer jurisdiction on this Court.
Upon due consideration, it is
ORDERED that, on or before April 21, 2023, petitioners shall file an Objection, if any, to respondent's above-described motion. If petitioners fail to file an objection, the Court may grant respondent's motion and dismiss for lack of jurisdiction so much of this case relating to tax year 2022.