Opinion
10769-22S
01-26-2023
JOSEPH INGRAM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 20, 2023, the parties filed a proposed stipulated decision for the Court's consideration. Upon review, however, it appears that the record does not contain a copy of the notice of deficiency that petitioner challenges in this case. This Court's jurisdiction in a deficiency case, such as this one, depends on the issuance of a valid notice of deficiency and the timely filing of a petition within 90 days of the date of issuance.
Upon due consideration of the foregoing, it is
ORDERED that, on or before February 17, 2023, the parties shall file status reports (preferably a joint report) concerning the then-current status of this case and attach thereto a copy of the notice of deficiency on which this case is based. The Court will hold the parties' proposed stipulated decision pending submission of the notice of deficiency.