Opinion
4858-23
06-12-2023
LEONARD TARVER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 26, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground the petition was not timely filed in response to the notice of deficiency upon which the case is based. Petitioner filed several documents on June 7, 2023, and June 8, 2023, but none of them addressed the jurisdictional allegations made in respondent's motion.
Upon due consideration, it is
ORDERED that the documents filed by petitioner at Docket Index Nos. 7-11 are recharacterized as Exhibits. Petitioner is advised that evidentiary materials generally are not filed with the Court; rather, they should be exchanged with counsel for the Internal Revenue Service which is separate from the Court. It is further
ORDERED that, on or before June 30, 2023, petitioner shall file a proper Objection, if any, to the above-described motion to dismiss. Failure to comply with this Order may result in the granting of the motion or other action as the Court deems appropriate.