Opinion
11710-23
09-30-2024
CHRISTOPHER A. GRAHAM & JANA GRAHAM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
Pending in the above-docketed matter is a Motion To Dismiss for Lack of Jurisdiction, filed September 13, 2023, by respondent herein. Subsequently, on April 23, 2024, petitioners filed an objection to respondent's motion, and respondent rejoined with a response to petitioners' objection on May 22, 2024. As administrative aspects remained ongoing, on July 25, 2024, petitioners filed a Status Report, and on July 26, 2024, respondent fled a First Supplement to Response to Objection to Motion to Dismiss for Lack of Jurisdiction. Most recently, on September 27, 2024, respondent filed a Second Supplement to Response to Objection to Motion to Dismiss for Lack of Jurisdiction, advising that administrative adjustments to petitioners' 2019 and 2020 tax accounts have been completed and renewing respondent's request that the case be dismissed for lack of jurisdiction.
Upon due consideration of the foregoing, and in light of the recent developments, it is
ORDERED that, on or before October 21, 2024, petitioners shall file a supplement to their April 23, 2024, objection clarifying their current position on the jurisdictional issue presently before the Court, given the just-referenced recent administrative developments.