Opinion
9341-22S
02-06-2023
ALEXANDER MACDOWELL & KRISTIN MACDOWELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On February 1, 2023, respondent filed two Motions to Dismiss for Lack of Jurisdiction--one without attachments and another with attachments (Docs. 7 and 8, respectively). Respondent asserts therein that this case should be dismissed for lack of jurisdiction on the grounds that the petition was not filed within the time prescribed in the Internal Revenue Code.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed February 1, 2023, at Doc. 7, is stricken from the Court's record in this case. It is further
ORDERED that, on or before February 27, 2023, petitioners 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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