Opinion
27544-22S
04-13-2023
JAZMINE HOO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Based on a review of the pleadings in the above-docketed matter, it appears that petitioner seeks to invoke this Court's jurisdiction under I.R.C. section 6015(e). However, the record does not appear to include a copy of any notice of final determination, and it is not clear whether, at the time of the filing of the Petition, six months had passed since any election was filed or request was made by petitioner. See I.R.C. § 6015(e)(1)(A).
In view of the foregoing, it is
ORDERED that, on or before May 15, 2023, respondent shall file either (1) a response to this Order, addressing the basis, if any, for the Court's jurisdiction in this case, and attaching, if appropriate, a complete copy of the notice of final determination giving rise to such jurisdiction; or (2) an appropriate motion to dismiss.