Opinion
10015-22S
07-11-2022
JAMES MICHAEL HALL & PATRICIA S. HALL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan, Chief Judge
On June 22, 2022, the parties filed a proposed stipulated decision for the Court's consideration. Upon review of the record, however, it appears that petitioners may have paid the tax liability for the 2019 tax year prior to the issuance of the notice of deficiency. If so, the notice of deficiency issued to petitioners for the 2019 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 August 1, 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. We will hold the parties' proposed stipulated decision pending resolution of the jurisdictional issue in this case. 1