Opinion
15051-20
10-12-2022
JOSE H. LUGARO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
L. Paige Marvel Judge
This case is scheduled for trial at the session of the Court scheduled to begin on October 31, 2022, in Philadelphia, Pennsylvania.
On October 7, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction. In respondent's motion, respondent states among other things, that the petition in this case was not filed with the Court within the time prescribed by I.R.C. sec. 6213(a) or sec. 7502. Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is set for hearing at the calendar call of the aforementioned session of the Court, at 10:00 AM (ET). Petitioner is advised that failure to appear at the hearing on October 31, 2022, may result in the Court granting respondent's motion and entering an order and decision that is consistent with respondent's motion.
This Order constitutes official notice to the parties.