Opinion
28449-21
03-15-2022
Mark Douglas Wellbaum Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On December 20, 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 April 5, 2022, petitioner 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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