Opinion
8633-21L
09-13-2021
Kyle Richard Falzano & Christina Falzano Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
Upon due consideration of the Motion To Dismiss for Lack of Jurisdiction, filed July 30, 2021, by respondent in the above-docketed case, wherein respondent seeks partial dismissal insofar as concerns a Notice of Final Determination for Disallowance of Interest Abatement Claim, it is
ORDERED that respondent's motion shall be recharacterized as a Motion To Dismiss for Lack of Jurisdiction as to Notice of Final Determination for Full or Partial Disallowance of Interest Abatement Claim. It is further
ORDERED that, on or before October 1, 2021, respondent shall file a supplement to the just-referenced motion addressing whether Internal Revenue Service reflect that petitioners at any time submitted an interest abatement claim, and if so, when.
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