Opinion
4422-22
11-18-2022
ADAM VIENER & SARA VIENER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Pending in the above-docketed matter is respondent's Motion to Dismiss for Lack of Jurisdiction, filed March 28, 2022, on the grounds that the petition in this case was not filed within the time prescribed by the Internal Revenue Code. Subsequently, on May 12, 2022, petitioners filed a Motion to Proceed Remotely.
Upon due consideration, it is
ORDERED that, petitioner's motion to proceed remotely filed May 2, 2022, is held in abeyance pending the resolution of respondent's motion to dismiss for lack of jurisdiction.