Opinion
9135-23S
07-24-2023
SALAM K. SULAIMAN & IMAN K. LASOO, Petitioner(s) v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 30, 2023, petitioners filed the petition to commence this case, indicating therein that they seek review of a notice of final determination for interest disallowance claim (or failure of IRS to make final determination within 180 days after claim for abatement) with respect to the tax year "May 15, 2023". Petitioners, however, appended to the petition attachments relating to their 2019 tax year.
On July 20, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that, as to petitioners' 2019 tax year, no notice of final determination for interest disallowance claim was issued to petitioners, petitioners have not submitted to the IRS any Form 843, Claim for Refund and Request for Abatement of Interest, nor has respondent made any other determination sufficient to confer jurisdiction on this Court. Respondent's motion, however, does not address petitioner's claims concerning their 2023 tax year.
Upon due consideration of the foregoing, it is
ORDERED that, on or before August 15, 2023, respondent shall file a supplement to his Motion to Dismiss for Lack of Jurisdiction and therein set forth and fully discuss his position with respect to petitioners' claims concerning their 2023 tax year.