Opinion
22343-22S
09-25-2023
SHAHEEN TUFAIL & ZARQA NIAZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Alina I. Marshall, Judge
On September 18, 2023, the parties filed a proposed stipulated decision. The Petition in this case was filed electronically on October 20, 2022. The Court notes, however, that the Notice of Deficiency attached to respondent's Answer identifies the deadline for filing a petition as October 13, 2022. Premises considered, it is
ORDERED that the parties shall show cause, in writing, on or before October 10, 2023, why this case should not be dismissed for lack of jurisdiction on the ground that the petition in this case was untimely pursuant to I.R.C. section 6213(a) or 7502.