Opinion
12557-23
10-31-2023
LINDA WORSHAM & IRA WORSHAM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On October 6, 2023, respondent filed a Motion to Dismiss for Lack of Jurisdiction, seeking partial dismissal on the ground that no notice deficiency and no notice of determination was issued to Ira Worsham for tax years 2012, 2013, 2014, or 2016, no notice of deficiency or notice of determination was issued for tax year 2012 to Linda Worsham, and no notice of deficiency was issued to Linda Worsham for the tax years 2012, 2013, 2014, or 2016.
Upon due consideration, it is
ORDERED that, on or before November 22, 2023, petitioners shall file an objection, if any, to respondent's Motions to Dismiss for Lack of Jurisdiction. Failure to comply with this Order may result in the granting of respondent's motions or other appropriate action by this Court.
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