Opinion
6359-21
08-23-2021
Gloria Gruber & Theodore Gruber, Deceased Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On June 29, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction. Respondent asserts in his motion that the petition filed to commence this case was not filed within the time prescribed by the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before September 23, 2021, petitioners shall file an Objection, if any, to respondent's above-described motion and state therein the reason for the objection. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.
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