Opinion
22155-21
01-06-2022
John C. Poland & Gwendolyn B. Poland Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge.
On October 29, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction. In his motion, respondent asserts that this case should be dismissed as petitioner paid the tax liability for the 2018 tax year prior to the issuance of the notice of deficiency and, therefore, the notice of deficiency on which this case is based is invalid.
Upon due consideration, it is
ORDERED that, on or before January 28, 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.