Opinion
32395-21
03-18-2022
Luis Saavedra & Maria A. Santana Saavedra Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On October 1, 2021, petitioners filed with this Court, which is separate and independent from the IRS, the petition to commence this case. On December 28, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction. Respondent asserts in his motion that no notice of deficiency or notice of determination for tax year 2019 sufficient to confer jurisdiction on this Court has been issued to petitioners.
Upon due consideration, it is
ORDERED that, on or before April 7, 2022, petitioners shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you currently file in paper and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov. If you did not electronically file the petition to commence your case and you have not previously registered for eAccess, please do not attempt to electronically file documents in your case without first contacting dawson.support@ustaxcourt.gov to register for eAccess.