Opinion
5338-23S
10-27-2023
ANNA D. CORORATON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Alina I. Marshall Judge
On October 23, 2023, the parties filed with the Court a proposed stipulated decision. The Petition in this case was electronically filed on April 11, 2023. The Court notes, however, that the Notice of Deficiency attached to the Petition identifies the deadline for filing a petition in this case as April 10, 2023. Premises considered, it is
ORDERED that the parties shall show cause, in writing, on or before November 30, 2023, why this case should not be dismissed for lack of jurisdiction on the ground that the Petition in this case was untimely pursuant to I.R.C. section 6213(a) or 7502.