Opinion
19639-22S
06-12-2023
MICHAEL A. CARLUCCI & CANDICE SASAKI-CARLUCCI, Petitioners 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 September 25, 2023, Los Angeles, California trial session. On August 26, 2022, the Court received and filed a petition from petitioners. However, upon review of the Notice of Deficiency included in respondent's answer, filed October 20, 2022, it was seen that the last date for petitioner to file a petition with the Court was August 22, 2022. The envelope that the petition was sent in does not appear to bear a postmark of the date sent. Therefore, it appears that the petition was not timely filed with the Court.
Upon due consideration, it is hereby.
ORDERED that, on or before July 12, 2023, 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.
Petitioners are advised that the failure to respond to this Order to Show Cause may result in the dismissal of this case.
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