Opinion
25239-21
04-20-2022
SERGEI OREL & LYUDMILA OREL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
Upon due consideration of respondent's motion to dismiss for lack of jurisdiction, filed November 29, 2021, and respondent's first supplement to motion to dismiss for lack of jurisdiction, filed February 17, 2022, it is
ORDERED that respondent's motion to dismiss for lack of jurisdiction, as supplemented, is denied. 1