Opinion
26239-21
12-23-2021
ORDER
Maurice B. Foley Chief Judge
On December 2, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction. Respondent asserts in his motion that no notice of deficiency or notice of determination has been issued to petitioner for tax year 2016 that would permit petitioner to invoke the jurisdiction of this Court.
Upon due consideration, it is
ORDERED that, on or before January 20, 2022, petitioner 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.