Opinion
24196-22
02-01-2023
PABLO ESPINOZA & RUFINA VARGAS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion To Dismiss for Lack of Jurisdiction, filed January 3, 2023, and in light of Hallmark Research Collective v. Commissioner, 159 T.C.___ (2022), it is
ORDERED that, on or before February 22, 2023, petitioners shall file an Objection, if any, to respondent's Motion To Dismiss for Lack of Jurisdiction. Failure to comply with this Order may result in the granting of respondent's motion and dismissal of this case or other appropriate action by the Court.