Opinion
14035-24
11-01-2024
CODI HOTT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 9, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Years 2015, 2016, 2019 and 2020 and To Strike. On October 31, 2024, respondent filed a supplement to his just-described Motion. As grounds for his Motion, as supplemented, respondent asserts that no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2015, 2016, 2019, and 2020 tax years.
Upon due consideration, it is
ORDERED that, on or before November 25, 2024, petitioner shall file an Objection, if any, to respondent's above-described Motion, as supplemented. Failure to file a timely objection may result in the granting of respondent's Motion, as supplemented, and dismissal for lack of jurisdiction of so much of this case relating to tax years 2015, 2016, 2019, and 2020. The Court will take appropriate action following the period for objection. Petitioner is advised that respondent's Motion, as supplemented, does not seek dismissal of so much of this case relating to the notice of deficiency issued for petitioner's 2021 tax year.