Opinion
27279-22S
04-07-2023
KEVIN J. PERRY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 10, 2023, 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. Thereafter, on April 6, 2023, respondent filed a First Supplement to Motion to Dismiss for Lack of Jurisdiction
Upon due consideration, it is
ORDERED that, on or before April 28, 2023, petitioner shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented. If petitioner fails to file an objection, the Court may grant respondent's motion and dismiss this case for lack of jurisdiction.
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