Opinion
15549-22S
12-23-2022
WILLIAM DAVID MARTIN & NINA JOSEPHINE MARTIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 6, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the petition in this case was not filed within the time prescribed in the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before January 20, 2023, petitioners shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.