Opinion
20388-21
01-09-2023
WILLIAM HEFLEY & AIMEE HEFLEY, 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 November 8, 2021, and the attachments thereto which do not establish that a notice of deficiency was issued to petitioners on March 27, 2019, it is
ORDERED that respondent's motion is denied, without prejudice.