Opinion
16117-23
01-29-2024
NILSON A. MATOS & ALICIA A. MATOS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
The petition in this case was filed on October 13, 2023. On December 6, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction seeking to dismiss tax year 2021 on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code. Further review on the record herein has raised questions regarding the potential applicability of disaster relief afforded to residents of Massachusetts on account of Hurricane Lee.
Upon due consideration, it is
ORDERED that, on or before February 20, 2024, respondent shall file a Supplement to his motion to dismiss and shall address therein the relevance of any disaster relief in the context of this proceeding.