Opinion
6812-24
08-07-2024
ALASTAIR R. GOURLEY & JUNKO YOSHIDA Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of the Motion to Dismiss for Lack of Jurisdiction, filed July 18, 2024, by respondent in the above-docketed matter, and to ensure an adequate opportunity for petitioners to be heard notwithstanding a representation by respondent that there is no objection to the granting of the Motion, it is
ORDERED that, on or before August 28, 2024, petitioners shall file an objection, if any, to respondent's just-referenced Motion. Failure to file a timely objection may result in the granting of respondent's Motion, dismissal of this case for lack of jurisdiction, and the IRS seeking payment of the determined amount(s). The Court will take appropriate action following the period for objection.