Opinion
16257-23S
12-21-2023
ORDER
Kathleen Kerrigan Chief Judge.
Upon due consideration of the Motion to Dismiss for Lack of Jurisdiction, filed December 15, 2023, by respondent in the above-docketed matter, and to ensure an adequate opportunity for petitioner to be heard notwithstanding a representation by respondent that there is no objection to the granting of the Motion, it is
ORDERED that, on or before January 12, 2024, petitioner shall file an objection, if any, to respondent's just-referenced Motion. Failure to file a timely objection may result in the granting of respondent's Motion, dismissal of this case for lack of jurisdiction, and the IRS seeking payment of the determined amount(s). The Court will take appropriate action following the period for objection.