Opinion
19139-21S
01-10-2022
Mary C. Hampton & David Penaloza-Sandoval Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On November 18, 2021, the Court issued an Order to Show Cause, directing the parties to show cause why this case should not be dismissed for lack of jurisdiction on the ground the petition was not filed within the time prescribed by the Internal Revenue Code. On December 6, 2021, respondent filed a response to the Court's Order to Show Cause. No response has been received from petitioners. Upon due consideration of respondent's response, and for the reasons set forth therein, it is
ORDERED that the Court's Order to Show Cause, issued November 18, 2021, is discharged.
Petitioners are advised that their claims relating to the notice of deficiency, dated February 1, 2021, for their 2018 tax year remain pending before this Court.