Opinion
1499-23S
04-06-2023
CRAIG FRANCO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 4, 2023, 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 April 27, 2023, petitioner shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.
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