Opinion
27875-21
07-27-2022
ARTHUR W. FOLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
In response to respondent's Motion to Dismiss for Lack of Jurisdiction, filed June 3, 2022, petitioner filed a Reply to Motion to Dismiss for Lack of Jurisdiction. Upon due consideration, it is
ORDERED that petitioner's Reply to Motion to Dismiss for Lack of Jurisdiction is recharacterized as an Objection to Motion to Dismiss for Lack of Jurisdiction. It is further
ORDERED that, on or before August 17, 2022, respondent shall file either a supplement to his Motion to Dismiss for Lack of Jurisdiction or a Reply to petitioner's Objection to Motion to Dismiss for Lack of Jurisdiction.