Opinion
13005-23
02-13-2024
GARRET SMITH & CAROL SMITH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE
On September 26, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that no notice of determination concerning collection action sufficient to confer jurisdiction on this Court was issued to petitioners for their 2014. To ensure an adequate opportunity for petitioners to be heard notwithstanding a representation by respondent that there is no objection to the granting of the motion, it is
ORDERED that, on or before March 6, 2024, petitioners shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to file a timely objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.
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