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Louis Hoang v. Comm'r of Internal Revenue

United States Tax Court
Nov 1, 2022
No. 9145-22S (U.S.T.C. Nov. 1, 2022)

Opinion

9145-22S

11-01-2022

LOUIS HOANG & HUONG T. HOANG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER TO SHOW CAUSE

Kathleen Kerrigan Chief Judge

On October 28, 2022, the parties filed for the Court's consideration a settlement stipulation and a proposed stipulated decision. Upon further review of the record, however, it appears that petitioners may have paid the tax liability for the 2019 tax year prior to the issuance of the notice of deficiency. If so, the notice of deficiency issued to petitioners for the 2019 tax year is invalid and this Court lacks jurisdiction of this case. See Naftel v. Commissioner, 85 T.C. 527 (1985).

Upon due consideration, it is

ORDERED that, on or before November 23, 2022, the parties shall show cause in writing why this case should not be dismissed for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid. The Court will hold the parties' proposed stipulated decision pending resolution of the jurisdictional issue in this case.


Summaries of

Louis Hoang v. Comm'r of Internal Revenue

United States Tax Court
Nov 1, 2022
No. 9145-22S (U.S.T.C. Nov. 1, 2022)
Case details for

Louis Hoang v. Comm'r of Internal Revenue

Case Details

Full title:LOUIS HOANG & HUONG T. HOANG, Petitioners v. COMMISSIONER OF INTERNAL…

Court:United States Tax Court

Date published: Nov 1, 2022

Citations

No. 9145-22S (U.S.T.C. Nov. 1, 2022)