Opinion
26342-21
03-27-2023
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 the ground that the petition was not timely filed as to a notice of deficiency issued to petitioners for tax year 2017. On January 10, 2022, petitioners filed a Reply to Motion to Dismiss for Lack of Jurisdiction. On March 24, 2023, respondent filed a Response to petitioners' Reply, in which he asks for 30 days to file a supplement in order to coordinate with respondent's national office.
Upon due consideration, it is
ORDERED that, on or before April 24, 2023, respondent shall file a Supplement to his Response to Reply to Motion to Dismiss for Lack of Jurisdiction.