Opinion
22995-21
02-07-2022
Cyndy Reed Stewart Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On November 30, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that the petition filed to commence this case was not filed within the time prescribed by the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before February 24, 2022, petitioner shall file an Objection, if any, to respondent's above-described motion and state therein the reason for the objection. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.