Opinion
10895-21
09-21-2021
Rodney A. Fletcher & Debo Cuyle-Fletcher Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley Chief Judge
On August 19, 2021, the parties filed a proposed stipulated decision for the Court's consideration. Upon further review, however, the petition filed to commence this case on March 30, 2021, indicates that the deficiency in this case might possibly have been paid by petitioners before the notice of deficiency for petitioners' 2018 tax year was issued. If such is the case, the notice of deficiency, dated March 15, 2021, issued to petitioners' for their 2018 tax year is invalid, and this Court is without jurisdiction in this matter.
Upon due consideration, it is
ORDERED that, on or before October 12, 2021, 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. We will hold the parties' proposed stipulated decision pending resolution of the jurisdiction issue in this case.
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