Opinion
12078-20S
10-13-2022
CYNTHIA ANNE CABRAL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Eunkyong Choi, Special Trial Judge.
This case is calendared for trial at the Court's December 19, 2022, New York City, New York remote trial session. On October 6, 2020, the Court received and filed a petition from petitioner. However, upon review of the Notice of Determination regarding innocent spouse relief underlying this matter, included in respondent's Response to Order filed on October 4, 2022, it was determined that the last date for petitioner to file a petition with the Court was September 17, 2020. Therefore, it appears that the petition was not timely filed with the Court and the Court lacks jurisdiction to hear the case.
Upon due consideration, it is hereby
ORDERED that, on or before November 11, 2022, the parties shall show cause in writing as to why the Court, on its own motion, should not dismiss this case for Lack of Jurisdiction upon the ground that the petition in this case was not filed within the time prescribed by I.R.C. § 6330 or § 7502.