Opinion
4189-24S
05-03-2024
DANA L. FERGUSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 2, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the Petition in this case was not filed within the time prescribed in the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before May 28, 2024, petitioner shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to file a timely objection may result in the granting of respondent's motion, 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.