Opinion
28120-21SL
03-30-2022
PAUL PRICE & PAMELA HOWARD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge.
Upon due consideration of the Motion To Dismiss for Lack of Jurisdiction with Respect to Portion of the Petition That Seeks To Invoke the Jurisdiction of the Tax Court Under Section 7436(a) of the Internal Revenue Code, filed December 16, 2021, by respondent in the above-docketed case, it is
ORDERED that, on or before April 26, 2022, petitioners shall file an objection, if any, to respondent's just-referenced motion. Failure to comply with this Order may result in the granting of respondent's motion and partial dismissal of the instant case as to section 7436(a), I.R.C., or other appropriate action by this Court. The case as to the notice of determination concerning collection action for 2016 and 2017 is not affected by respondent's motion and will continue before the Court, regardless of any action on the motion.