Opinion
859-23
03-31-2023
CHRISTOPHER HUGAN & BERNADETTE HUGAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 13, 2023, respondent filed in this case a motion to Dismiss for Lack of Jurisdiction. Respondent asserts in his motion that this case should be dismissed on the ground that the notice of deficiency on which this case is based is invalid because petitioners paid the tax liability for 2020 before issuance of the notice.
Upon due consideration, it is
ORDERED that, on or before April 21, 2023, petitioners shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.