Opinion
13719-21S
10-22-2021
Dennis Alfred Cattell Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On October 15, 2021, the parties filed a proposed stipulated decision for the Court's consideration. However, on September 28, 2021, the Court issued an Order to Show Cause directing the parties to show cause, on or before October 20, 2021, 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. On October 7, 2021, petitioner filed a response to the Court's Order to Show Cause. No response has been received from respondent.
Upon due consideration, it is
ORDERED that the time within which respondent shall file a response to the Court's Order to Show Cause is extended to November 5, 2021. The Court will hold the parties' proposed stipulated decision pending resolution of the jurisdictional issue in this case.