Opinion
6805-23S
06-16-2023
JENNIFER L. ABEL & BRIAN D. ABEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On June 15, 2023, 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 July 10, 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.
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