Opinion
8078-23S
06-16-2023
PHILIP W. MANN & LINDA E. MANN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 14, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Upon due consideration, it is
ORDERED that, on or before July 7, 2023, petitioners shall file an Objection, if any, to the above-described motion. Failure to comply with this Order may result in the granting of the motion or other action as the Court deems appropriate.
Petitioners are reminded that evidentiary materials, such as the Exhibit and memoranda in support thereof filed May 23, 2023, generally are not filed with the Court; rather, they should be exchanged with counsel for the Internal Revenue Service.