Opinion
11651-23
10-31-2023
CHRISTINA IRENE DILLON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
Pending in the above-docketed matter is a Motion To Dismiss for Lack of Jurisdiction, filed September 13, 2023, by respondent. Although petitioner has declined to file any objection to respondent's motion, further review has raised questions regarding the potential relevance to this proceeding of the addition time for filing a petition applicable in circumstances where taxpayers are outside of the United States during pertinent periods. The petition references petitioner being in Japan, and the motion does not appear to have addressed the implications thereof, if any. Alternatively, to the extent that a California address should be considered controlling, the possibility of disaster relief for California residents is also raised.
Accordingly, the premises considered, it is
ORDERED that, on or before November 20, 2023, respondent shall file a supplement to the just-referenced motion clarifying the relevance, if any, of the extended filing period(s) in the context of this proceeding.