Opinion
18822-23
02-08-2024
RICHARD FRADELLA & TAMMY FRADELLA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of the Motion to Dismiss for Lack of Jurisdiction, filed January 18, 2024, and the First Supplement to Motion to Dismiss for Lack of Jurisdiction, filed February 6, 2024, by respondent in the above-docketed matter, it is
ORDERED that, on or before February 29, 2024, petitioners shall file an objection, if any, to respondent's just-referenced Motion, as supplemented. Failure to file a timely objection may result in the granting of respondent's Motion, as supplemented, dismissal of this case for lack of jurisdiction, and the IRS seeking payment of the determined amount(s). The Court will take appropriate action following the period for objection.
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