Opinion
2607-24L
04-30-2024
JASON DIAL & SUSANNE DIAL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 15, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to tax years 2019, 2020, and 2021, seeking partial dismissal on the ground that no notice of determination was issued to petitioners for tax year 2019, 2020, and 2021 related to the notice of intent to levy issued on December 22, 2022.
Upon due consideration, it is
ORDERED that, on or before May 21, 2024, petitioners shall file an objection, if any, to respondent's Motions to Dismiss for Lack of Jurisdiction as to tax years 2019, 2020, and 2021. Failure to comply with this Order may result in the granting of respondent's motions or other appropriate action by this Court.
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