Opinion
26893-22S
06-27-2023
ROY S. ADANIYA & LAVERN G. ADANIYA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 22, 2023, respondent filed in the above-docketed matter a Motion To Dismiss for Lack of Jurisdiction as to Petitioner Roy S. Adaniya and to Change Caption. However, review of the record herein also raises questions regarding the Court's jurisdiction over the remaining case as to petitioner Lavern G. Adaniya from a perspective of timeliness.
Accordingly, the premises considered, it is
ORDERED that, on or before July 21, 2023, petitioners shall file an objection, if any, to respondent's just-referenced motion as to petitioner Roy S. Adaniya. Failure to comply with this Order may result in the granting of respondent's motion or other appropriate action by this Court. It is further
ORDERED that, on or before July 21, 2023, respondent shall file either: (1) An appropriate jurisdictional motion with respect to the remaining case as to Lavern G. Adaniya; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Lavern G. Adaniya and attaching thereto a copy of any supporting documentation.