Opinion
14559-22
08-22-2022
RODOLFO PAGDAYUNAN, 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 August 18, 2022, it is
ORDERED that, on or before September 12, 2022, petitioner shall file an Objection, if any, to respondent's above-referenced motion. Failure to file an objection may result in the granting of respondent's motion and the dismissal of this case for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid.
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