Opinion
1627-23
03-27-2024
HUBERT MITCHELL ZACHARY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On February 17, 2023, petitioner filed the petition in this case seeking review of a notice of deficiency, notice of determination, and notice of certification of your seriously delinquent federal tax debt to the Department of State. On April 21, 2023, respondent filed the Answer, to which he attached a decision letter on equivalent hearing. On March 22, 2024, respondent filed a Motion to Dismiss on Ground of Mootness, seeking to dismiss this case as to the notice of certification of your seriously delinquent federal tax debt.
Upon due consideration, it is
ORDERED that, on or before April 18, 2024, respondent shall file a report addressing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation.