Opinion
12954-21S
08-30-2021
ORDER
Maurice B. Foley Chief Judge
On August 25, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that the petition in this case was not filed within the time prescribed by the Internal Revenue Code. Therein, respondent states that petitioners object to the granting of the motion.
The foregoing considered, it is
ORDERED that, on or before September 23, 2021, petitioners shall file an Objection, if any, to respondent's above-referenced motion. Therein, petitioners shall state the reasons for any objection. Petitioners are hereby advised that failure to comply with this Order may result in the granting of the motion to dismiss.