Opinion
32789-21S
04-11-2022
SEAN A. COSGROVE & NICOLE COSGROVE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
On January 28, 2022, 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.
Upon due consideration, it is
ORDERED that, on or before May 3, 2022, petitioners shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction and therein state the reason for the objection. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.
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