Opinion
16431-22S
02-28-2023
KEITH A. KAY & ELLEN N. KAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of the Proposed Stipulated Decision filed February 15, 2023, and further review of the record of this case, it is
ORDERED that, on or before March 20, 2023, the parties shall show cause in writing why this case should not be dismissed for lack of jurisdiction on the ground the petition was not timely filed in response to the notice of deficiency dated March 21, 2022.