Opinion
20630-21
11-23-2021
David Mandel & Ellen Mandel Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
Upon due consideration of the Motion To Dismiss for Lack of Jurisdiction as to a Notice of Determination Concerning Collection Action, filed September 28, 2021, by respondent in the above-docketed case, it is
ORDERED that, on or before December 16, 2021, petitioners shall file an objection, if any, to respondent's just-referenced motion. Failure to comply with this Order may result in the granting of respondent's motion and partial dismissal of the instant case as to a purported notice of determination or other appropriate action by this Court. The case as to the notice of deficiency for 2018 is not affected by respondent's motion and will continue before the Court, regardless of any action on the motion.
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