Opinion
24919-22
01-30-2023
BARON JIWOO KIM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 20, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the petition in this case was not filed within the time prescribed in the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before February 22, 2023, petitioner shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.