Opinion
9717-21
09-01-2021
Ernest J. Marcel & Alexandra Marcel Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On July 26, 2019, the Court issued an Order To Show Cause directing the parties to show cause why this case should not be dismissed for lack of jurisdiction on the ground that the notice of deficiency upon which this case is based is invalid. On August 10, 2021, respondent filed a Response to Order To Show Cause, wherein respondent asserted that the notice of deficiency is valid because a deficiency existed when the notice of deficiency was issued.
Accordingly, and for cause, it is
ORDERED that the Court's Order To Show Cause, dated July 26, 2021, is hereby discharged.
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