Opinion
14094-21
09-17-2021
Christopher R. Ashe & Nicole D. Ashe Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On September 1, 2021, 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. See secs. 6213(a), 7502. Therein, respondent states that petitioners' views on the motion are unknown.
The foregoing considered, it is
ORDERED that, on or before October 15, 2021, petitioners shall file an Objection, if any, to respondent's above-referenced motion. Therein, petitioners shall state the reasons for any objection. Petitioners are hereby advised that failure to comply with this Order may result in the granting of the motion to dismiss.
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