Opinion
20549-21S
01-28-2022
Kelen G. Guerra Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On November 22, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that the petition filed to commence this case was not filed within the time prescribed by the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before February 22, 2022, petitioner shall file an Objection, if any, to respondent's above-described 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.