Opinion
32607-21
01-19-2023
ABIGAEL LOYA REYES & ANGEL LOYA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 15, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction. On April 29, 2022, respondent attached a status report, which includes a receipt showing that petitioners sent the amended petition to the Tax Court on February 7, 2022.
According to the notice of deficiency and respondent's motion, the last date to petition the Court was September 20, 2021. However, the petition was filed on October 12, 2021, and postmarked October 4, 2021.
Upon due consideration, it is
ORDERED that, on or before February 10, 2023, petitioners shall file an objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to comply with this Order may result in the granting of respondent's motion and dismissal of this case or other appropriate action by this Court.