Opinion
33441-21
03-09-2022
Alix Bearman & Jonathan Mozenter Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On January 26, 2022, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground no notice of deficiency or other notice of determination was issued to petitioners for taxable year 2016 that would permit petitioners to invoke the Court's jurisdiction in this case. On March 3, 2022, CPA Allen M. Ullman filed a Letter Dated February 21, 2022 on petitioners' behalf. Mr. Ullman is not admitted to practice before the Tax Court. The Court further does not recognize powers of attorney. Accordingly, the Court cannot recognize Mr. Ullman as representative for petitioners in this case.
For cause, it is
ORDERED that the time within which petitioners shall file an Objection to respondent's motion to dismiss, is extended to April 1, 2022. Failure to comply with this Order may result in the Court's granting the motion to dismiss.