Opinion
19144-23S
07-17-2024
JOHN PAUL GILBERT & DAWN JERI GILBERT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan, Chief Judge
On July 15, 2024, the parties filed a Proposed Stipulated Decision. However, upon review of the record, it appears that the notice of deficiency upon which this case is based was issued only to petitioner John Paul Gilbert. Consequently, the Court does not appear to have jurisdiction to make a determination as to petitioner Dawn Jeri Gilbert's federal income tax for the taxable year 2020. That being so, it is
ORDERED that the above-referenced Proposed Stipulated Decision is deemed stricken from the Court's record in this case. It is further
ORDERED that, on or before August 9, 2024, the parties shall show cause in writing why this case should not be dismissed for lack of jurisdiction as to petitioner Dawn Jeri Gilbert on the ground that no notice of deficiency, nor any other determination sufficient to confer jurisdiction on this Court, has been issued to her for the taxable year 2020. Failure to comply with this Order may result in the dismissal of this case as to petitioner Dawn Jeri Gilbert or other appropriate action by the Court.