Opinion
5660-22
04-12-2022
THEODORE E. DOWNING & CARMEN G. DOWNING, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration of the Motion To Dismiss for Lack of Jurisdiction as to Taxable Year 2018 and To Strike, filed April 6, 2022, by respondent in the above-docketed case, it is
ORDERED that, on or before May 6, 2022, 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 partial dismissal of the instant case as to 2018 or other appropriate action by this Court. The case as to 2019 is not affected by respondent's motion and will continue before the Court, regardless of any action on the motion.