Opinion
5189-23S
05-16-2023
RUBEN LOZOYA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On May 12, 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 June 7, 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.
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