Opinion
11651-23
01-16-2024
CHRISTINA IRENE DILLON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
Pending before the Court in this deficiency action is respondent's Motion to Dismiss for Lack of Jurisdiction, filed September 13, 2023. On November 17, 2023, respondent filed a First Supplement to Motion to Dismiss for Lack of Jurisdiction.
By Order served November 27, 2023, the Court directed petitioner to file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented. On December 29, 2023, petitioner electronically filed a document, designating the filing as an "Answer." However, review of the filing shows that it is more akin to a motion for extension of time, insofar as petitioner therein requests additional time to file an objection to respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented.
Upon due consideration and for cause, it is
ORDERED that petitioner's Answer is recharacterized as petitioner's Motion for Extension of Time. It is further
ORDERED that petitioner's just-referenced Motion is granted in that the time within which petitioner shall file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented, is hereby extended to March 12, 2024. Failure to file a timely objection may result in the granting of respondent's Motion, as supplemented; dismissal of this case for lack of jurisdiction; and the IRS seeking payment of the determined amount(s). The Court will take appropriate action following the period for objection.