Opinion
3952-24
05-20-2024
VEENA VIJAYAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 18, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. On May 17, 2024, petitioner filed an Objection to Motion to Dismiss for Lack of Jurisdiction, in which petitioner asserts she did not receive the notice of deficiency. The Forms 3877 attached to respondent's Motion to Dismiss for Lack of Jurisdiction shows that respondent mailed the notice of deficiency for tax year 2021 on June 12, 2023.
Upon due consideration, it is
ORDERED that, on or before June 10, 2024, petitioner shall file a Supplement to her objection. In her Supplement, petitioner shall set forth her mailing address as of June 12, 2023, the date on which the notice of deficiency was mailed to her, and shall provide the dates that petitioner resided at that address. In addition, petitioner shall describe what steps, if any, petitioner took to notify respondent of any change of mailing address and to inform respondent of any new mailing address. Petitioner shall also attach copies of any written notifications of any change of address provided to respondent. Failure to comply with this Order may result in the granting of respondent's motion and dismissal of this case or other appropriate action by this Court.