Opinion
24256-22
09-12-2023
SHAUN J. PEOPLES & CHASE L. PEOPLES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
This case is currently calendared on the Court's Cleveland, Ohio trial session, scheduled to begin October 2, 2023.
On September 11, 2023, the Commissioner filed a motion to dismiss for lack of jurisdiction upon the ground that the petition was not filed within the time prescribed by Internal Revenue Code section 6213(a) or section 7502. We will direct petitioners Shaun J. Peoples and Chase L. Peoples to file an objection, if any, to the motion. Accordingly, it is
ORDERED that, on or before September 25, 2023, Mr. and Mrs. Peoples shall file an objection, if any, to the motion to dismiss for lack of jurisdiction. If Mr. and Mrs. Peoples fail to file a response to the motion, the Court may grant the motion and dismiss this case for lack of jurisdiction.