Opinion
11651-22
01-03-2023
GREGORY A. BRUCE & MARY S. BRUCE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Travis A. Greaves Judge.
This case is set for trial at the Court's April 3, 2023, Knoxville, Tennessee, trial session. On December 30, 2022, respondent moved that (1) the case be dismissed for lack of jurisdiction as to petitioner Mary S. Bruce upon the ground that no statutory notice of deficiency, as authorized by Internal Revenue Code (I.R.C.) § 6212 and required by I.R.C. § 6213(a) to form the basis for a petition to this Court, has been sent to petitioner Mary S. Bruce with respect to taxable year 2016, nor has respondent made any other determination with respect to petitioner Mary S. Bruce's taxable year 2016 that would confer jurisdiction on this Court, and (2) the caption of this case be changed to read: Gregory A. Bruce, Petitioner.
Upon due consideration, it is
ORDERED that by January 30, 2023, petitioners shall show cause why respondent's Motion filed December 30, 2022, should not be granted.