Opinion
24465-21
03-30-2022
Estate of Tommy J. Gilmore, JuAnn Carter, Independent Executor and JuAnn Carter Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley, Chief Judge
Upon further review of the record in this case, it appears that petitioners may have paid the tax liability for the 2018 tax year prior to the issuance of the notice of deficiency. If so, the notice of deficiency issued to petitioners for the 2018 tax year is invalid and this Court lacks jurisdiction of this case. See Naftel v. Commissioner, 85 T.C. 527 (1985).
Upon due consideration, it is
ORDERED that, on or before April 18, 2022, the parties shall show cause in writing why this case should not be dismissed for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid.