Opinion
13359-22S
12-23-2022
JOSHUA MICHAEL SUSSMAN & MARNE SUE SUSSMAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On September 16, 2022, 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.
Upon due consideration, it is
ORDERED that, on or before January 20, 2023, petitioners shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction. It is further
ORDERED that, in addition to this Order, the Clerk of the Court shall serve on petitioner a copy of respondent's above-referenced motion.
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