Opinion
9473-23S
08-07-2023
PATRICK TRAINOR & JILL TRAINOR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 4, 2023, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the petition was not timely filed within the period prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.). However, further review has raised questions regarding the potential applicability of any disaster relief afforded to California residents.
Accordingly, the premises considered, it is
ORDERED that, on or before August 21, 2023, respondent shall file a supplement to the just-referenced motion clarifying the relevance, if any, of disaster relief in the context of this proceeding.