Opinion
15945-23
11-09-2023
STEVEN G. FERGUSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On November 7, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. As grounds for his motion, 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 2020 and 2021 tax years.
Upon due consideration, it is
ORDERED that, on or before December 1, 2023, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.