Opinion
31224-21S
11-03-2022
WILLIAM CURTIS JONES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi Special Trial Judge
This case is calendared for trial at the Court's January 17, 2023, Standalone, Remote Trial session. On November 19, 2021, the Court electronically received and filed a petition from petitioner. However, upon review of the Notice of Deficiency included in respondent's Answer, filed on January 12, 2022, it was seen that the last date for petitioner to file a petition with the Court is not listed, also, the date of the Notice of Deficiency itself is not listed, therefore, since the Court has no knowledge of the last date to file a petition, it appears that the petition may not be timely filed with the Court.
Upon due consideration, it is hereby
ORDERED that, on or before December 2, 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.