Opinion
1064-22
09-09-2022
PIERRE-ETIENNE CHARTIER & CANDICE-JENNIFER DEAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan Chief Judge
Upon review of the record in the above-docketed case, the Court notes that the Notice of Deficiency upon which this case is based appears to have been issued only to petitioner Pierre-Etienne Chartier. The record does not appear to include any indication that such a notice has been issued to petitioner Candice-Jennifer Dean.
Accordingly, it is
ORDERED that, on or before October 12, 2022, each party shall show cause in writing why this case should not be dismissed for lack of jurisdiction as to petitioner Candice-Jennifer Dean. Each party shall attach thereto any notice issued to Candice-Jennifer Dean that would permit her to invoke the jurisdiction of the Court in this proceeding.