Opinion
1627-23
04-30-2024
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, a notice of determination, and a notice of certification of your seriously delinquent federal tax debt to the Department of State. On March 22, 2024, respondent filed a Motion to Dismiss on Ground of Mootness, seeking to dismiss so much of the case as relates to the notice of certification of your seriously delinquent federal tax debt. On April 18, 2024, respondent filed a report, in which he states that the Court lacks jurisdiction as to the notices of deficiency because no notice of deficiency has been issued and the Court does not have jurisdiction with respect to some of the liabilities related to notices of determination because no liability has been assessed. In addition, respondent asserts that some of the liabilities related to notices of determination should be dismissed as moot because no balance remains due.
Upon due consideration, it is
ORDERED that, on or before May 21, 2024, respondent shall file an appropriate jurisdictional motion and an appropriate supplement to his Motion to Dismiss on Ground of Mootness.