Opinion
27444-22S
04-27-2023
JOHN M. KOTT & LORI KOTT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On April 26, 2023, petitioners electronically filed a document, designating it as a "Motion to Dismiss for Lack of Jurisdiction." However, review of the filing shows that it is more akin to an objection to respondent's Motion to Dismiss for Lack of Jurisdiction, filed March 16, 2023.
In consideration of the foregoing, it is
ORDERED that petitioners' above-referenced filing is recharacterized as petitioners' Objection to Motion to Dismiss for Lack of Jurisdiction.