Opinion
26584-22S
04-07-2023
DIEGO GONZALEZ PACHECO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Upon due consideration of respondent's Motion To Dismiss for Lack of Jurisdiction, filed March 23, 2023, and in light of Hallmark Research Collective v. Commissioner, 159 T.C. (2022), it is
ORDERED that, on or before April 28, 2023, petitioner shall file an Objection, if any, to respondent's Motion To Dismiss for Lack of Jurisdiction. Failure to comply with this Order may result in the granting of respondent's motion and dismissal of this case or other appropriate action by the Court.