Opinion
9329-21
10-21-2021
Frank Ragozine & Frances Ragozine Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On September 9, 2021, respondent filed a motion to dismiss for lack of jurisdiction. Respondent asserts in his motion that this case should be dismissed on the ground that the notice of deficiency on which this case is based is invalid because petitioners paid their tax liability for 2018 before issuance of the notice.
Upon due consideration, it is
ORDERED that, on or before November 12, 2021, petitioner shall file an Objection, if any, to respondent's above-described motion and state therein the reason for the objection. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.