Opinion
14844-23
11-07-2023
CONRAD LYTLE & TAMMY LYTLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On October 30, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that petitioners fully paid the proposed deficiency for the taxable year 2021 before the issuance of the notice of deficiency upon which this case is based, thereby rendering that notice invalid.
In consideration of the foregoing, it is
ORDERED that, on or before November 28, 2023, petitioners shall file an objection, if any, to respondent's above-referenced Motion. Failure to comply with this Order may result in the granting of the Motion to Dismiss.