Opinion
18115-21
10-28-2021
Phillip Keith Cummings Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On September 13, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that the petition filed to commence this case was not filed within the time prescribed by the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before November 19, 2021, petitioner shall file an Objection, if any, to respondent's above-described motion and state therein 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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