Opinion
15156-23
12-05-2023
ROE COMBS & BONNIE COMBS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 19, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Years 2014 and 2018 on the ground that no notice of deficiency or notice of determination was issued to petitioners for those taxable years that would permit them to invoke the Court's jurisdiction. Upon review of the Petition, it appears petitioners are seeking relief only with respect to taxable years 2014 and 2018.
Upon due consideration and for cause, it is
ORDERED that respondent's above-described Motion to Dismiss for Lack of Jurisdiction as to Taxable Years 2014 and 2018 is recharacterized as respondent's Motion to Dismiss for Lack of Jurisdiction. It is further
ORDERED that, on or before January 2, 2024, petitioners 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 dismissal of the instant case or other appropriate action by this Court.