Opinion
17249-23
12-19-2023
NAYSHA Y. OQUENDO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On December 18, 2023, the Commissioner (respondent) filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the petition in this case was not filed within the time prescribed in the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before January 17, 2024, petitioner Naysha Y. Oquendo 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.