Opinion
11217-23
10-18-2023
D'LAYNIE KEITH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 14, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that no notice of determination under Section 6015 was issued to petitioner for tax year 2021. In his motion, respondent failed to address whether the Court has jurisdiction pursuant to section 6015(e)(1)(A)(i)(II).
Upon due consideration, it is
ORDERED that, on or before November 8, 2023, respondent shall file a Supplement to his motion in which he states whether the Court has jurisdiction as to tax year 2021 pursuant to section 6015(e)(1)(A)(i)(II).