Opinion
19935-21S
03-16-2022
Thomas Chadwick Mansfield & Kristi Lynn Mansfield Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley Chief Judge
On January 31, 2022, the parties filed a proposed stipulated decision for the Court's consideration. Upon review of the record, however, it appears that petitioners may have paid the tax liability for the 2018 tax year prior to the issuance of the notice of deficiency. If so, the notice of deficiency issued to petitioners for the 2018 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 April 7, 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 in abeyance the parties' proposed stipulated decision pending resolution of the jurisdictional issue in this case.