Opinion
13186-20S
02-08-2022
Ann Elise Smoot Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On January 5, 2021, respondent filed a motion to dismiss for lack of jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Service. On January 28, 2022, respondent filed a first supplement in response to the Court's Order issued December 27, 2021.
Upon due consideration, it is
ORDERED that respondent's first supplement in response to the Court's Order issued December 27, 2021, is recharacterized as a first supplement to motion to dismiss for lack of jurisdiction. It is further
ORDERED that, on or before April 8, 2022, petitioner shall file an Objection, if any, to respondent's motion to dismiss for lack of jurisdiction, as supplemented, and therein state the reason for the objection. Failure to file an objection may result in the granting of respondent's motion, as supplemented, and dismissal of this case for lack of jurisdiction. It is further
ORDERED that, in addition to the copy of this Order, the Clerk of the Court shall serve on petitioner a copy of respondent's motion to dismiss for lack of jurisdiction and respondent's first supplement to motion to dismiss for lack of jurisdiction.
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