Opinion
30415-21S
08-22-2022
DANIELLE PAREJA LANGHOFF & EDWARD LANGHOFF, 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 December 19, 2022, New York City, New York trial session. On August 19, 2022, respondent filed a Motion to Dismiss for Lack of Jurisdiction as to Edward Langhoff. The motion alleges that there is no record, information, or other evidence indicating that a notice of deficiency authorized by I.R.C. § 6212 was mailed to petitioner-husband, Edward Langhoff, with respect to the taxable year 2019 and therefore he should be removed from the case. Respondent is unable to determine whether petitioners object to the granting of this motion.
Based upon respondent's Motion and upon due consideration, it is hereby
ORDERED that, on or before September 21, 2022, petitioner shall show cause in writing why respondent's Motion to Dismiss for Lack of Jurisdiction as to Edward Langhof, filed August 19, 2022, should not be granted..
Petitioner is advised that the failure to respond to this order may result in the granting of the above-reference Motion as requested by respondent. 1