Opinion
26342-21
01-04-2023
RENATO MARTINEZ OPENIANO & MARIA GRACIA PENETRANTE OPENIANO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 6, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction. On January 10, 2022, petitioners filed a Reply to Motion to Dismiss for Lack of Jurisdiction.
Upon due consideration, it is
ORDERED that, on or before January 25, 2023, respondent shall file a Response to petitioners' Reply to Motion to Dismiss for Lack of Jurisdiction.