Opinion
9285-23
11-09-2023
SONIA LUZ PEDINOTTI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On November 8, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction. As grounds for the motion, respondent asserts that (1) as to alleged notices issued to petitioner for the 2023 tax year, no such notices were sent, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court, and (2) as to a notice of deficiency issued for petitioner's 2018 tax year, the petition was not filed within the time prescribed in the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before December 4, 2023, petitioner shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.