Opinion
11367-23S
11-09-2023
MARK DEROBERTIS & SUSAN WRENN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 1, 2023, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the petition was not timely filed within the period prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.). Although petitioners have declined to file any objection to respondent's motion as directed by the Court, further review has raised questions regarding the potential applicability of any disaster relief afforded to California residents.
Accordingly, the premises considered, it is
ORDERED that, on or before November 29, 2023, respondent shall file a supplement to the just-referenced motion clarifying the relevance, if any, of disaster relief in the context of this proceeding.