Opinion
29629-21
03-07-2022
Stephen G. Vogrin & Melissa L. Vogrin Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge.
On December 9, 2021, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that the petition in this case was not filed within the time prescribed by the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before March 28, 2022, petitioners shall file an Objection, if any, to respondent's Motion to Dismiss for Lack of Jurisdiction and therein state the reason for the objection. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.
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