Opinion
2425-24S
03-19-2024
JOSUE HERNANDEZ MORALES & ESMERALDA HERNANDEZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 14, 2024, the Commissioner (respondent) filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the Petition in this case was filed before the notice of deficiency for petitioners' 2021 tax year was issued.
Upon due consideration of the foregoing, it is
ORDERED that, on or before April 10, 2024, petitioners Josue Hernandez Morales and Esmeralda Hernandez shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to file a timely objection may result in the granting of respondent's motion, dismissal of this case for lack of jurisdiction, and the IRS seeking payment of the determined amount(s). The Court will take appropriate action following the period for objection.