Opinion
122-22
03-29-2023
GLENN R. MATTES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On February 25, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the petition was not timely filed within the period prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.). At this juncture, further review of the record herein has raised questions regarding the potential applicability of disaster relief afforded to residents of Pennsylvania on account of Hurricane Ida.
Accordingly, upon due consideration, it is
ORDERED that, on or before April 19, 2023, respondent shall file a supplement to the motion to dismiss and shall address therein the relevance of any disaster relief in the context of this proceeding.