Opinion
14439-23
11-13-2023
MICHAEL TALALAEV & JODI STEEN TALALAEV, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE
On November 8, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Jodi Steen Talalaev and To Change Caption. As grounds for his motion, respondent asserts that no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to Ms. Talalaev's 2019 tax year.
Upon due consideration, it is
ORDERED that, on or before December 4, 2023, petitioners shall file an Objection, if any, to respondent's above-described motion. Failure to file an objection may result in the granting of respondent's motion and dismissal for lack of jurisdiction of so much of this case relating to petitioner Jodi Steen Talalaev.