Opinion
3094-24
04-17-2024
ROBERT FITCH O'ROURKE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 15, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction. By Order served April 15, 2024, the Court directed respondent to file a supplement to that Motion. On April 17, 2024, respondent filed a Response to the Court's Order.
Upon due consideration and for cause, it is
ORDERED that respondent's above-referenced Response is recharacterized as respondent's First Supplement to Motion to Dismiss for Lack of Jurisdiction. It is further
ORDERED that, on or before May 10, 2024, petitioner shall file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction, as supplemented. Failure to file a timely objection may result in the granting of respondent's Motion, as supplemented; 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.