Opinion
20169-23S
02-06-2024
DAVID W. JEWELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On February 2, 2024, petitioner David W. Jewell filed a Letter Dated January 20, 2024, in which he requests that this case be dismissed. In Mainstay Bus. Sols. v. Commissioner, 156 T.C. 98 (2021), the Court ruled that a petition challenging the Internal Revenue Service's determination with respect to a claim for interest abatement under Internal Revenue Code § 6404(h)(1)(A)(i) (or failure of the IRS to make a determination within 180 days after a claim for interest abatement) may be dismissed upon a motion by petitioner.
Upon due consideration of the foregoing, it is
ORDERED that petitioner's above-referenced Letter Dated January 20, 2024, is recharacterized as a Motion to Dismiss. It is further
ORDERED that, on or before February 28, 2024, respondent shall file an Objection, if any, to petitioner's Motion to Dismiss. Failure to file an objection may result in the granting of petitioner's motion.