Opinion
25779-21
12-20-2021
Michael Vongphakdy Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On October 25, 2021, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground that the petition filed to commence this case was not filed within the time prescribed by the Internal Revenue Code.
Upon due consideration, it is
ORDERED that, on or before January 18, 2022, petitioner shall file an Objection, if any, to respondent's above-described motion and state therein 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.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you currently file in paper and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov. If you did not electronically file the petition to commence your case and have not previously registered for eAccess, please do not attempt to electronically file documents in your case without first contacting dawson.support@ustaxcourt.gov.