Opinion
21260-21S
10-12-2022
JAMIL HASSAN KARRIEM, Petitioner 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 December 19, 2022, New York City, New York trial session. On September 2, 2021, the Court received and filed a petition from petitioner. However, upon review of the Notice of Deficiency included in respondent's answer, filed on November 6, 2021, it was seen that the last date for petitioner to file a petition with the Court was not listed. Petitioner filed their petition with the Court electronically and did not include a copy of their Notice of Deficiency, therefore it appears that the petition was not timely filed with the Court.
Upon due consideration, it is hereby
ORDERED that, on or before November 11, 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.