Opinion
12180-24
09-25-2024
JOSEPH D. ZAMMIT & MARGARET E. ZAMMIT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On September 25, 2024, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction, on the ground that the petition was not timely filed within the period prescribed by section 6213(a) or 7502 of the Internal Revenue Code (I.R.C.). However, further review has raised questions regarding the potential applicability of any disaster relief afforded to Massachusetts residents.
Accordingly, the premises considered, it is
ORDERED that, on or before October 16, 2024, respondent shall file a supplement to the just-referenced motion clarifying the relevance, if any, of disaster relief in the context of this proceeding.