Opinion
21168-22S
03-01-2023
JAMES J. HAMM, II & NANCY O. HAMM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER OF DISMISSAL FOR LACK OF JURISDICTION
Kathleen Kerrigan, Chief Judge
On December 1, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground the notice of deficiency was invalid. Petitioners filed an objection to the motion on January 16, 2023, alleging therein that they made payments to "cease further accrual of interest and penalties" and that they are due a refund of $19,943. Premises considered, it is
ORDERED that, on or before March 21, 2023, respondent shall file a response to petitioners' objection.