Opinion
13919-19S
03-15-2023
ALBERTO DELGADO & VIRGINIA DELGADO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
James S. Halpern Judge
Pursuant to the Tax Court's Summary Opinion 2023-8, filed March 13, 2023, it is
ORDERED that on or before April 11, 2023, petitioners shall file with the Court and serve on respondent a response to this Show Cause Order as to why the Court should not impose a penalty on them under I.R.C. section 6673(a)(1) for instituting or maintaining this proceeding primarily for delay by advancing groundless process-related arguments.