Opinion
3413-22
05-16-2022
ESTATE OF BEN FRANKEL, DECEASED AND ESTATE OF SHEILA FRANKEL, DECEASED, Petitioner(s) 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 April 22, 2022, by respondent in the above-docketed case, it is
ORDERED that, on or before June 10, 2022, petitioners shall file an objection, if any, to respondent's just-referenced motion. Failure to comply with this Order may result in the granting of respondent's motion and dismissal of the instant case or other appropriate action by this Court. It is further
ORDERED that the Motion To Change or Correct Caption, filed April 6, 2022, by petitioners is denied pending establishment of jurisdiction over the petitioner estates. Appropriate fiduciary representation for the estates becomes relevant only if the estates are properly before the Court in the first instance. 1