Opinion
23921-22L
01-18-2024
JOHN TRAHAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 2, 2024, respondent filed, inter alia: (1) a "First Supplemental Motion to Dismiss for Lack of Jurisdiction as to Petitioner Susan Trahan and as to Petitioner John Trahan's Deficiency and Interest Abatement Claims for 2015-2020 and Collection Claims for 2015, 2019, and 2020, and to Strike" (at Docket Index No. 26); and, (2) the "Declaration of Anne-Marie S. Brown in Support of First Supplemental Motion to Dismiss for Lack of Jurisdiction as to Petitioner Susan Trahan and as to Petitioner John Trahan's Deficiency and Interest Abatement Claims for 2015-2020 and Collection Claims for 2015, 2019, and 2020, and to Strike" (at Docket Index No. 27).
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced filing at Docket Index No. 26 is recharacterized as respondent's Motion to Dismiss for Lack of Jurisdiction as to Decision Letter Concerning Equivalent Hearing. It is further
ORDERED that respondent's above-referenced filing at Docket Index No. 27 is recharacterized as respondent's Declaration of Anne-Marie S. Brown in Support of Motion to Dismiss for Lack of Jurisdiction as to Decision Letter Concerning Equivalent Hearing. It is further
ORDERED that action on respondent's Motion to Dismiss for Lack of Jurisdiction as to Decision Letter Concerning Equivalent Hearing will be held in abeyance pending further direction by the Court.