Opinion
1645-23S
07-20-2023
NATHAN J. SALSI & DANIELLE C. SALSI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
By Order of Dismissal for Lack of Jurisdiction entered May 9, 2023, this case was dismissed for lack of jurisdiction on the grounds that the petition was not filed within the time prescribed in the Internal Revenue Code. On July 18, 2023, petitioners filed a Motion for Leave to File Motion to Vacate, accompanied by a Motion to Vacate Order of Dismissal that was improperly filed, rather than being lodged. Also on July 18, 2023, petitioners improperly filed a Motion to Remove Small Tax Case Designation, rather than properly filing a motion for leave to file such motion and concurrently lodging their motion concerning the small tax case designation. On July 19, 2023, petitioners filed a First Supplement to Motion for Leave to File Motion to Vacate.
Upon due consideration of the foregoing, it is
ORDERED that petitioners' Motion for Leave to File Motion to Vacate, First Supplement to Motion for Leave to File Motion to Vacate, Motion to Vacate Order of Dismissal, and Motion to Remove Small Tax Case Designation are deemed stricken from the Court's record in this case. Petitioners are free to properly resubmit the just-described documents.