Opinion
7519-21
09-21-2021
Joshua Glen Hansen & Candace Evette Hansen Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley Chief Judge.
On March 2, 2021, petitioners filed the petition to commence this case. Petitioners seek review of a notice of deficiency, dated December 7, 2020, issued for with respect to tax year 2017. A partial copy of the notice of deficiency on which this case is based is attached to the petition.
This Court is a court of limited jurisdiction. Relevant to this case, our jurisdiction in a deficiency case depends, in part, on the issuance of a notice of deficiency and the timely filing of a petition within 90 days of the issuance of the notice. See Internal Revenue Code (I.R.C.) sec. 6213. The partial notice of deficiency attached to the petition indicates it was issued only to petitioner Joshua Glen Hansen. No notice of deficiency issued to petitioner Candace Evette Hansen has been produced by petitioners. Accordingly, it appears that the Court may not have jurisdiction in this case with respect to petitioner Candace Evette Hansen.
Upon due consideration, it is
ORDERED that, on or before October 13, 2021, the parties shall show cause in writing why so much of this case relating to petitioner Candace Evette Hansen should not be dismissed for lack of jurisdiction on the ground no notice of deficiency sufficient to confer jurisdiction on this Court was issued to Candace Evette Hansen for her 2017 tax year. Respondent shall attach to his response a complete copy of the notice of deficiency on which this case is based.
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