Opinion
25740-21S
10-05-2022
LEON DAVOYAN, Petitioner 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 November 14, 2022, Los Angeles, California trial session. On July 19, 2021, the Court received and filed a petition from petitioner. However, upon review of the Notice of Deficiency included in petitioner's petition, it was seen that the last date for petitioner to file a petition with the Court was July 12, 2021. The envelope that the petition was sent in does not appear to bear a postmark of the date sent, and the tracking number, when entered into the United States Postal Service website indicates the tracking information has been archived. Therefore it appears that the petition was not timely filed with the Court.
Upon due consideration, it is hereby
ORDERED that, on or before October 31, 2022, 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.