Opinion
3413-22
08-08-2022
ESTATE OF BEN FRANKEL, DECEASED AND ESTATE OF SHEILA FRANKEL, DECEASED, Petitioner(s) v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
LEWIS R. CARLUZZO CHIEF SPECIAL TRIAL JUDGE
Giving due regard to the representations contained in petitioners' motion for continuance, filed August 2, 2022, it is
ORDERED that petitioners' motion is denied.
The hearing on respondent's motion to dismiss for lack of jurisdiction remains scheduled as provided in the Order served July 21, 2022. Petitioners' attention is invited to Rule 50(c) of the Tax Court Rules of Practice and Procedure (available on the Internet at www.ustaxcourt.gov), which allows for the submission of a written statement in lieu of, or in addition to, attendance at a hearing. Petitioners are excused from attendance at the hearing and may submit their position in response to the above-referenced motion in writing so as to be received by the Court prior to the date of the hearing.