Opinion
26605-21S
03-10-2022
Lee Clark Johnson & Janet Marie Johnson Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On December 13, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction and to Strike as to Taxable Year 2018 on the ground that, as to the notice of deficiency issued for petitioners' 2018 tax year, the petition in this case was not filed within the time prescribed by the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before March 30, 2022, petitioners shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction and therein state the reason for the objection. Failure to file an objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to petitioners' 2018 tax year. Petitioners are advised that respondent's motion does not seek dismissal of petitioners' claims relating to their 2019 tax year.
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