Opinion
7995-23S
06-16-2023
MARIO NAIM LOPEZ & NICOLE DANIELLE MARINI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On June 13, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Taxable Year 2021 and To Strike. Respondent asserts in his motion that no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioners' 2021 tax year.
Upon due consideration, it is
ORDERED that, on or before July 10, 2023, petitioners 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 for lack of jurisdiction of so much of this case relating to tax year 2021. Petitioners are advised that respondent's motion does not seek to dismiss so much of this case relating to petitioners' 2020 tax year.