Opinion
3735-22S
02-07-2023
CHARLES E. GIANELLONI & JAE KYUNG P. GIANELLONI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 22, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the petition was not filed within the time prescribed in the Internal Revenue Code. That motion references an Exhibit A, however, no exhibit is attached to the motion that was filed with the Court.
Upon due consideration of the foregoing, it is
ORDERED that, on or before February 28, 2023, respondent shall file a supplement to his Motion to Dismiss for Lack of Jurisdiction and attach thereto the exhibit referenced in that motion.