Opinion
21696-21S
09-07-2022
NICHOLAS JOHN KALLER & JACLYN IRENE KALLER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Peter J. Panuthos Special Trial Judge.
By notice dated August 2, 2022, this case is calendared for trial on the Tampa, Florida trial calendar of the Court scheduled to commence on December 5, 2022. On August 31, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to tax year 2017. Respondent asserts that petitioners' petition to this Court was not timely filed with respect to tax year 2017.
Premises considered, it is
ORDERED that petitioners shall, on or before October 14, 2022, file an objection, if any, to respondent's above-referenced motion. Any objection filed by petitioners shall state with specificity the reason(s) for the objection and facts to support a timely-filed petition. Failure to comply with this Order may result in the granting of respondent's motion.