Opinion
16059-22
06-16-2023
SAMMIE LEE THOMPSON & JENETTA K. THOMPSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Adam B. Landy, Special Trial Judge.
This case is set for trial at the Court's Los Angeles, California session of the Court scheduled to commence on October 16, 2023.
On June 14, 2023, the Commissioner filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the petition was not timely filed by the Thompsons to seek a redetermination of a deficiency for tax year 2018, pursuant to I.R.C. §§ 6213 and 7502, and the Thompsons have not received a notice of deficiency or any other notice for tax year 2021 which would invoke this Court's jurisdiction for review.
Upon due consideration of the Commissioner's motion and for cause, it is
ORDERED that, on or before July 14, 2023, the Thompsons shall file a response or an objection to the Commissioner's motion setting forth all facts which show that the Court has jurisdiction to hear their case for one or both tax years. The Thompsons are advised that should they fail to file a response or objection the Court may grant the Commissioner's motion without seeking any further responses.
If the Thompsons or the Commissioner would prefer that the Court set this pending motion for a hearing, please contact Linda Thomas, Chambers Administrator, at 202-521-0835, to schedule a remote hearing session on a Wednesday morning at 11:00 a.m. PST during the months of July through September 2023.