Opinion
14158-20
10-21-2021
Gerald Vito Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Cary Douglas Pugh, Judge
This case is currently set for trial at the Court's November 1, 2021, Miami, Florida trial session, to be conducted remotely. On October 9, 2021, respondent filed a Status Report and a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not filed within the time prescribed by I.R.C. sec. 6213(a) or 7502. Upon due consideration and for cause, it is hereby
ORDERED that respondent's Motion to Dismiss for Lack of Jurisdiction, filed October 9, 2021, is set for hearing at the Court's November 1, 2021, Miami, Florida trial session, schedule to commence at 10:00 am ET, to be conducted remotely. It is further
ORDERED that, on or before the call of this case from the calendar, petitioner shall file an objection or other response to respondent's Motion to Dismiss for Lack of Jurisdiction. 1