Opinion
35377-21
06-23-2023
LOUIS J. MAZZUCA & CONNIE MAZZUCA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 21, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to and to Strike as to the Notice of Deficiency for the 2017 tax year, seeking partial dismissal on the ground that the petition was not timely filed as to the notice of deficiency issued for tax year 2017.
Upon due consideration, it is
ORDERED that, on or before July 17, 2023, petitioners shall file an objection, if any, to respondent's Motions to Dismiss for Lack of Jurisdiction. Failure to comply with this Order may result in the granting of respondent's motions or other appropriate action by this Court.
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