Opinion
9168-21S
03-29-2022
Augustus Hoffman & Kyong Hoffman Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Eunkyong Choi, Special Trial Judge
This case is calendared for trial at the Court's June 13, 2022, New York City, New York remote trial session. On March 15, 2021 the Court received and filed a petition from petitioners. However, upon review of the Notice of Deficiency included in respondent's answer, filed on July 15, 2021, it was seen that the last date for petitioners to file a petition with the Court was March 2, 2021. The envelope that the petition was sent in does not appear to bear a postmark of the date sent, therefore it appears that the petition was not timely filed with the Court. Upon due consideration, it is hereby
ORDERED that, on or before April 25, 2022, the parties shall show cause in writing as to why the Court, on its own motion, should not dismiss this case for Lack of Jurisdiction upon the ground that the petition in this case was not filed within the time prescribed by I.R.C. § 6330 or § 7502. .