Opinion
31525-21
03-16-2022
Richard C. Nichols, Jr. & Michele J. Nichols Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
MAURICE B. FOLEY, CHIEF JUDGE
On December 30, 2021, respondent filed a motion to dismiss for lack of jurisdiction. Respondent asserts in his motion that this case should be dismissed on the ground that the notice of deficiency on which this case is based is invalid because petitioners paid the tax liability for 2018 before issuance of the notice.
Upon due consideration, it is
ORDERED that, on or before April 7, 2022, petitioners shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.
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