Opinion
19441-21
09-02-2022
DIANA ALVARADO SANCHEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On December 8, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction. On August 31, 2022, the parties filed a Proposed Stipulated Decision.
Upon further review of he record in the case, it appears that the petition may have been filed untimely. In view of the foregoing, it is
ORDERED that, on or before September 22, 2022, the parties shall file a joint or separate Response to this Order addressing whether the Court has jurisdiction over this case.