Opinion
30452-21S
02-24-2023
YAAKOV GLUCK & SURI GLUCK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 5, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the petition was not timely filed within the period prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.). Although petitioners have declined to file any objection to respondent's motion as directed by the Court, further review of the record at this juncture has raised questions regarding the potential applicability of disaster relief afforded to certain residents of New York on account of Hurricane Ida.
Accordingly, upon due consideration, it is
ORDERED that, on or before March 15, 2023, respondent shall file a supplement to the motion to dismiss and shall address therein the relevance, if any, of the aforementioned disaster relief.