Opinion
37639-21S
03-08-2023
ERIC GILLMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge
On November 23, 2022, the parties filed a Motion for Continuance. By Order served November 30, 2022, this case was continued, jurisdiction was retained by the undersigned, and the parties were directed, on or before February 28, 2023, to file a status report informing the Court of the then-present status of the case.
On February 28, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction (motion to dismiss) requesting that this case be dismissed for lack of jurisdiction upon the ground that the petition was not filed within the time prescribed by I.R.C. section 6213(a) or section 7502. Petitioner objects to the granting of this motion. Upon due consideration, it is
ORDERED that, on or before March 22, 2023, petitioner shall file an objection, if any, to respondent's motion to dismiss for lack of jurisdiction. Failure to respond to this Order may result in the granting of respondent's above-referenced motion to dismiss.