Opinion
18822-23
03-04-2024
RICHARD FRADELLA & TAMMY FRADELLA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
The petition in this case was filed on November 27, 2023. On January 18, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction seeking to dismiss tax years 2020, 2021, and 2022 on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. Further review on the record herein has raised questions regarding the potential applicability of disaster relief afforded to residents of Louisiana on account of seawater intrusion.
Upon due consideration, it is
ORDERED that, on or before March 25, 2024, respondent shall file a Supplement to his motion to dismiss and shall address therein the relevance of any disaster relief in the context of this proceeding.