Opinion
12835-20L
09-24-2021
Beauford Basped & Jennifer Basped Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley Chief Judge
This case is currently calendared for trial at the Court's October 18, 2021, remote trial session for Dallas, Texas. On September 15, 2021, the parties filed a proposed stipulated decision for the Court's consideration. Upon review, however, it appears that the record in this case contains only a notice of determination concerning collection action issued to petitioner Jennifer Basped in connection with income taxes for her 2017 tax year.
In a case seeking review of a determination under section 6320 or 6330, I.R.C., the jurisdiction of the Court depends, in part, upon the issuance of a valid notice of determination under section 6320 or 6330. Internal Revenue Code secs. 6320(c) and 6330(d)(1); Rule 330(b), Tax Court Rules of Practice and Procedure; Offiler v. Commissioner, 114 T.C. 492 (2000). The parties have not provided the Court with a copy of any notice of determination issued to petitioner Beauford Basped. Thus, at this juncture, it is unclear whether this Court has jurisdiction in this case with respect to petitioner Beauford Basped.
Upon due consideration, it is
ORDERED that, on or before October 8, 2021, the parties shall show cause in writing why so much of this case relating to petitioner Beauford Basped should not be dismissed for lack of jurisdiction. We will hold the parties' proposed stipulated decision pending resolution of this jurisdictional issue.
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