Opinion
17666-21
11-10-2021
Edmund A. Palmieri & Pamela C. Palmieri Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On November 10, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction as to Petitioners' Notice of Determination Concerning Collection Action Allegation.
On November 10, 2021, respondent further filed a Motion To Dismiss on Ground of Mootness.
Upon due consideration, it is
ORDERED that, on or before December 8, 2021, petitioners shall file an Objection, if any, to the above-described motion to dismiss as to collection action allegation. Failure to comply with this Order may result in the granting of that motion. It is further
ORDERED that, on or before December 8, 2021, petitioners shall file an Objection, if any, to the above-described motion to dismiss on ground of mootness. Failure to comply with this Order may result in the granting of that motion.