Opinion
11230-23
08-25-2023
ORDER
Kathleen Kerrigan, Chief Judge.
On August 23, 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 and businesses.
Accordingly, the premises considered, it is
ORDERED that, on or before September 14, 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.