Opinion
3775-22
06-27-2022
ORDER
Kathleen Kerrigan Chief Judge
On April 18, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction on the ground that petitioner paid the tax liability for tax year 2019 before the issuance of the notice of deficiency, and, therefore, the notice of deficiency on which this case is based is invalid.
Upon due consideration of the foregoing, it is
ORDERED that, on or before July 19, 2022, petitioner shall file an Objection, if any, to respondent's above-referenced motion. Failure to file an objection may result in the granting of respondent's motion and dismissal of this case for lack of jurisdiction.