Opinion
9514-23
02-22-2024
THOMAS A. POST & MICHELLE R. POST, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
Pending before the Court in this deficiency action is respondent's Motion to Dismiss for Lack of Jurisdiction, filed July 17, 2023. On August 3, 2023, petitioners filed an Objection thereto, together with several supporting documents, raising the application of I.R.C. section 7508 to the facts of this case. On February 21, 2024, respondent filed a Response, conceding that, pursuant to I.R.C. section 7508(a) and (c), the Petition was timely filed, and the Court has jurisdiction to hear this case. It is accordingly
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction is denied.