Opinion
37755-21S
01-04-2023
KENT COLLINS & LENKA COLLINS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Eunkyong Choi Special Trial Judge
This case is currently calendared for trial on the March 6, 2023, Las Vegas, Nevada trial session. On December 23, 2021, the Court received and filed a petition from petitioners. However, upon review of the Notice of Deficiency filed in petitioners' petition, it was seen that the last date for petitioners to file a petition with the Court was November 1, 2021. 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 January 27, 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 is advised that failure to respond to this Order to Show Cause may result in the dismissal of this case.