Opinion
5551-22
05-17-2023
MICHAEL STEVEN AYERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 31, 2022, 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 June 8, 2023, petitioner 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. It is further
ORDERED that, in addition to this Order, the Clerk of the Court shall serve on petitioner a copy of respondent's Motion to Dismiss for Lack of Jurisdiction.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you currently file in paper and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov. If you have not previously registered for eAccess, please do not attempt to electronically file documents in your case without first contacting dawson.support@ustaxcourt.gov.