Opinion
6335-21
06-21-2021
Sara Guerra & Raul Guerra Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On June 1, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction. Respondent asserts in his motion that the petition was not filed within the time prescribed by the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before July 22, 2021, petitioners shall file an Objection, if any, to respondent's motion and state therein the reason for the objection. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.