Opinion
1125-22S
03-31-2022
SEAN FITZGERALD TYNDALL & MARCIA ANNE CHUNG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge
This Court is separate and independent from the Internal Revenue Service. On March 23, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition in this case was not filed within the time prescribed by the Internal Revenue Code. Upon due consideration, it is
ORDERED that, on or before April 20, 2022, petitioners shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction and therein state the reason for the objection. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.
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