Tax Court Order Docket# 3813-19

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  • #14522
    Christopher Carmona
    Participant

    A client engaged me to do either a PPIA or OIC, they no longer want to contest their tax liability.
    Their previous CPA filed an untimely petition to the US TAX Court.

    The Tax Court has subsequently responded with an Order noting that they filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not timely filed. My client has not objected however the Tax Court Order says that the IRS review of the record shows that the certified mail list does not reflect a legible US postal service mark.
    Upon due consideration, the respondent (IRS Commissioner) is ordered to file a supplemental to the motion to dismiss attaching the 2016 notice of deficiency to the petitioner and a legible post marked mailing of the deficiency.

    My question is; Does my client have to take any further action? Or does this just go away by not objecting?

    Thank you,

    #15118
    Eric Green
    Keymaster

    What should happen is you wait for the tax court to kill it and then, once it goes back to the IRS, then file your OIC or PPIA.

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