Opinion
8449-23
08-03-2023
TREVOR WISE & ANN KURKA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 26, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that, as to petitioners' 2018 taxable year, the petition in this case was not filed within the time prescribed in the Internal Revenue Code.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is recharacterized as a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2018. It is further
ORDERED that, on or before August 25, 2023, petitioners shall file a Response, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2018. Failure to file a response may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to petitioners' 2018 taxable year.