Opinion
24227-22
03-20-2023
RONALD K. WHITE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On November 3, 2022, petitioner filed the petition in this case seeking review of a notice of deficiency dated May 23, 2022, issued to him for tax year 2020. Attached to the petition is a copy of that May 23, 2022, deficiency notice issued for 2020, which states the last day for filing a timely Tax Court petition as to that notice would expire on August 22, 2022. The petition, filed November 3, 2022, arrived at the Court in an envelope with a U.S. Postal Service postmark of October 28, 2022.
On December 14, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction, on the ground that the petition was not timely filed. By Order served February 10, 2023, the Court directed petitioner, on or before March 6, 2023, to file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. On March 14, 2023, petitioner filed a Motion for Extension of Time to File an Objection.
Upon due consideration, it is
ORDERED that petitioner's Motion for Extension of Time is granted in that the time within which petitioner shall file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction is extended to April 10, 2023.
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.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you currently file in paper and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov. If you are not currently registered for eAccess, please do not attempt to electronically file documents in a pending case without first contacting dawson.support@ustaxcourt.gov.