Opinion
8444-21S
02-03-2023
JAMES P. ROBERTSON & FRANCES R. ROBERTSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE
On July 14, 2021, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the petition was not timely filed within the period prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.). However, further review of the record herein has raised questions regarding the potential applicability of disaster relief afforded for residents of Texas affected by winter storms.
Accordingly, upon due consideration, it is
ORDERED that, on or before February 23, 2023, respondent shall file a supplement to the motion to dismiss and shall address therein the just-referenced matter of disaster relief.