Opinion
32420-21
03-03-2022
Amber Benesh & Aaron Benesh Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
Petitioners filed the petition to commence this case on October 4, 2021. On January 12, 2022, respondent filed a motion to dismiss for lack of jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. By Orders served January 19 and January 20, 2022, the Court directed petitioners to pay the Court's $60.00 filing fee for this case and to file a proper ratification of petition.
In view of the foregoing, it is
ORDERED that, on or before March 23, 2022, petitioners 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 the Court's Orders served January 19, 2022, and January 20, 2022, are held in abeyance pending the resolution of the jurisdictional issue in this case. Petitioners need not comply with those Orders unless and until the Court issues further directions.