Opinion
1044-24
03-01-2024
RAGHUVIR MADHABHAI LAVARI & JIGNASA R. LAVARI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Upon due consideration of respondent's Motion to Dismiss for Lack of Jurisdiction and to Strike Notices of Determination, filed February 29, 2024, it is
ORDERED that respondent's above-referenced Motion is recharacterized as respondent's Motion to Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Collection Action. It is further
ORDERED that, on or before March 25, 2024, petitioners shall file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction as to Notice of Determination Concerning Collection Action. Failure to comply with this Order may result in the granting of the Motion to Dismiss.