Opinion
26680-21
03-24-2022
Celia Caro Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration of the Motion to Dismiss for Lack of Jurisdiction as to the Notice of Determination and Notice of Final Determination for Disallowance on an Interest Abatement Claim and To Strike, filed December 1, 2021, by respondent in the above-docketed case, it is
ORDERED that, on or before April 19, 2022, petitioner shall file an objection, if any, to respondent's just-referenced motion. Failure to comply with this Order may result in the granting of respondent's motion and partial dismissal of the instant case as to a purported notice of determination concerning collection action and notice of final determination for disallowance of an interest abatement claim or other appropriate action by this Court. The case as to the notice of deficiency for 2012 is not affected by respondent's motion and will continue before the Court, regardless of any action on the motion. 1