Opinion
4005-23
04-24-2023
SYLVIA D. WILLIAMS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On April 7, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction. Thereafter, on April 18, 2023, respondent filed a First Supplement to Motion to Dismiss for Lack of Jurisdiction. In his motion, as supplemented, respondent asserts that (1) as to petitioner's 2020 tax year, the petition was not filed within the time prescribed in the Internal Revenue Code, and (2) no notice of deficiency was issued, nor has respondent made any other determination, sufficient to confer jurisdiction on this Court as to petitioner's 2022 tax year.
Upon due consideration, it is
ORDERED that, on or before May 12, 2023, petitioner shall file an Objection, if any, to respondent's above-described motion, as supplemented. Failure to file an objection may result in the granting of respondent's motion, as supplemented, and dismissal of this case for lack of jurisdiction.
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