Opinion
1789-24
03-26-2024
SATISH SHAH & JUHI SHAH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On March 26, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Respondent asserts in his motion that no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioners' 2021 tax year.
Upon due consideration, it is
ORDERED that, on or before April 17, 2024, petitioners shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.