Opinion
21706-22
05-16-2023
SCOTT L. SHLEIFER & ELENA SHLEIFER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of the Motion To Dismiss for Lack of Jurisdiction as to a Notice of Deficiency, a Notice of Determination Concerning Collection Action, or a Notice of Final Determination for Disallowance of Interest Abatement Claim, for tax year 2014, filed November 4, 2022, by respondent in the above-docketed case, it is
ORDERED that, to clarify the record insofar as respondent's motion comprises disposition of the case in full, the November 4, 2022, motion shall be recharacterized as a Motion To Dismiss for Lack of Jurisdiction. It is further
ORDERED that, on or before June 12, 2023, 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 dismissal of the instant case or other appropriate action by this Court.