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Openiano v. Comm'r of Internal Revenue

United States Tax Court
Mar 27, 2023
No. 26342-21 (U.S.T.C. Mar. 27, 2023)

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.


Summaries of

Openiano v. Comm'r of Internal Revenue

United States Tax Court
Mar 27, 2023
No. 26342-21 (U.S.T.C. Mar. 27, 2023)
Case details for

Openiano v. Comm'r of Internal Revenue

Case Details

Full title:RENATO MARTINEZ OPENIANO & MARIA GRACIA PENETRANTE OPENIANO, Petitioners…

Court:United States Tax Court

Date published: Mar 27, 2023

Citations

No. 26342-21 (U.S.T.C. Mar. 27, 2023)