Opinion
24237-21S
05-22-2024
WINFREY T. WADE, DECEASED & MARTHA S. WADE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 18, 2024, respondent filed a Motion to Dismiss for Lack of Prosecution. However, further review indicates that this filing appears to be more akin to a Motion to Dismiss for Lack of Jurisdiction.
On May 21, 2024, respondent filed a First Supplement to Motion to Dismiss for Lack of Prosecution. However, further review indicates that this filing appears to be more akin to a First Supplement to Motion to Dismiss for Lack of Jurisdiction.
Upon due consideration, it is
ORDERED that respondent's Motion to Dismiss for Lack of Prosecution, filed April 18, 2024, is recharacterized as respondent's Motion to Dismiss for Lack of Jurisdiction. It is further
ORDERED that respondent's First Supplement to Motion to Dismiss for Lack of Prosecution, filed May 21, 2024, is recharacterized as respondent's First Supplement to Motion to Dismiss for Lack of Jurisdiction.