Opinion
18523-22S
11-22-2022
MARK CARRIGAN & MICHELLE SMITH CARRIGAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Pending before the Court is respondent's Motion to Dismiss for Lack of Jurisdiction, filed October 11, 2022, on the ground that the petition in this case was not filed within the time prescribed by the Internal Revenue Code. Subsequently, on October 20, 2022, petitioner filed a Motion to Proceed Remotely.
Upon due consideration and in view of the record in this case, it is
ORDERED that, petitioner's Motion to Proceed Remotely filed October 20, 2022, is held in abeyance pending the resolution of respondent's Motion to Dismiss for Lack of Jurisdiction.