Opinion
772-24
04-12-2024
PIE MANIRARORA & RACHEL MUKAHIRWA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 5, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not timely filed as to the notice of deficiency issued for tax year 2021. On March 27, 2024, petitioners filed an Objection to Motion to Dismiss for Lack of Jurisdiction, in which petitioners state that petitioners' first attempt to mail the petition took place on December 27, 2023, but the petition was returned to petitioners on January 10, 2024.
Upon due consideration, it is
ORDERED that, on or before May 3, 2024, respondent shall file a Response to petitioners' Objection. In the Response, respondent shall set forth and discuss fully respondent's position of whether the Court has jurisdiction after considering Price v. Commissioner, 76 T.C. 389 (1981).
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