Opinion
5985-21S
06-21-2021
Kirk Wayne Booth & Jenny Henry Booth Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
MAURICE B. FOLEY CHIEF JUDGE
On February 12, 2021, petitioners filed the petition to commence this case, seeking review of a notice of deficiency, dated November 16, 2020, issued for their 2018 tax year. In the petition, petitioners state "I received notice CP3219A regarding a deficiency of $3215. This is a duplicate of notice CP2000 which I addressed with payment five months ago." On June 8, 2021, the parties submitted a proposed stipulated decision for the Court's consideration. However, if petitioners paid the tax liability with respect to their 2018 tax year before the issuance of the notice of deficiency for their 2018 tax year, that notice of deficiency is invalid and this Court is without jurisdiction in this case.
In view of the foregoing, it is
ORDERED that, on or before July 21, 2021, the parties shall show cause in writing why this case should not be dismissed for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid. The Court will hold the parties proposed stipulated decision pending resolution of the jurisdictional question in this case.