Opinion
3695-24S
05-03-2024
RICARDO ORDORICA VALENZUELA & CHRISTINA ORDORICA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE.
On May 1, 2024, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the grounds that the petition in this case was not filed within the time prescribed in the Internal Revenue Code. To ensure an adequate opportunity for petitioners to be heard notwithstanding a representation by respondent that there is no objection to the granting of the motion, it is
ORDERED that, on or before May 24, 2024, petitioners shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction. Failure to file a timely objection may result in the granting of respondent's motion, dismissal of this case for lack of jurisdiction, and the IRS seeking payment of the determined amount(s). The Court will take appropriate action following the period for objection.