Opinion
13745-21S
09-17-2021
Sang Bak & Yong Shin Lee Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On August 16, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction. In his motion, respondent asserts that petitioners paid the tax liability for tax year 2017 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency on which this case is based is invalid.
Upon due consideration, it is
ORDERED that, on or before October 5, 2021, 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 the dismissal of this case for lack of jurisdiction.
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