Opinion
18334-21
11-03-2021
Laura Herevia Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge.
On October 4, 2021, respondent filed a motion that was designated as respondent's "Motion to Dismiss for Lack of Jurisdiction as to AS TO TAX YEARS 2016 and 2017". Therein, respondent requests that this case be dismissed as to the taxable years 2016 and 2017 on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code with respect to such years.
Upon due consideration of the foregoing, it is
ORDERED that respondent's "Motion to Dismiss for Lack of Jurisdiction as to AS TO TAX YEARS 2016 and 2017" is recharacterized as respondent's Motion to Dismiss for Lack of Jurisdiction as to Tax Years 2016 and 2017. It is further
ORDERED that, on or before December 1, 2021, petitioner shall file an objection, if any, to respondent's above-referenced motion. Failure to comply with this Order may result in the granting of the motion to dismiss.