Opinion
20607-22
02-15-2023
ANGEL M. SERRANO VERGES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On December 12, 2022, petitioner filed a Motion for More Definite Statement Pursuant to Rule 51. However, further review indicates that petitioner's Motion appears to be more akin to a Motion to Dismiss for Lack of Jursidiction on the Ground that the notice of deficiency was invalid because it was not mailed to petitioners last known address.
Upon due consideration, it is
ORDERED that petitioner's Motion for More Definite Statement Pursuant to Rule 51, is recharacterized as petitioner's Motion to Dismiss for Lack of Jurisdiction. It is further
ORDERED that, on or before March 9, 2023, respondent shall file an objection, if any, to petitioner's above-mentioned motion. 1