Opinion
699-22S
03-27-2023
TOBIAS D. WALKER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion to Dismiss for Lack of Jurisdiction, filed July 29, 2022, and First Supplement to Motion to Dismiss for Lack of Jurisdiction, filed February 16, 2023, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is recharacterized as a Motion to Dismiss for Lack of Jurisdiction as to Notice of Deficiency for Tax Year 2016, Notice of Determination Concerning Collection Action, and Notice of Determination for Disallowance of Interest Abatement Claim. It is further
ORDERED that respondent's First Supplement to Motion to Dismiss for Lack of Jurisdiction is recharacterized as a First Supplement to Motion to Dismiss for Lack of Jurisdiction as to Notice of Deficiency for Tax Year 2016, Notice of Determination Concerning Collection Action, and Notice of Determination for Disallowance of Interest Abatement Claim. It is further
ORDERED that, on or before April 18, 2023, petitioner Tobias D. Walker shall file an Objection, if any, to respondent's above-referenced motion, as supplemented. Failure to file an objection may result in the granting of respondent's motion, as supplemented, and dismissal for lack of jurisdiction of petitioner's claims in this case other than those concerning the notice of deficiency issued for petitioner's 2020 tax year.