Opinion
785-21
12-21-2021
Vickie Lynn Morton & Mark Robert Humphrey Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley, Chief Judge
The notice of deficiency for tax year 2017 attached to the petition filed on February 20, 2021, indicates that it was issued only to petitioner Vickie Lynn Morton. This Court is a court of limited jurisdiction. In a case seeking redetermination of a deficiency, the jurisdiction of the Court depends on the issuance of a valid notice of deficiency and the filing of a Tax Court petition within 90 days after the notice of deficiency is mailed (not counting Saturday, Sunday, or a legal holiday in the District of Columbia as the last day). See Internal Revenue Code section 6213(a). As the record does not contain a copy of a notice of deficiency for tax year 2017 issued to petitioner Mark Robert Humphrey, it appears that the Court may lack jurisdiction with respect to Mark Robert Humphrey in this case.
Upon due consideration, it is
ORDERED that, on or before January 25, 2022, the parties shall show cause in writing why so much of this case relating to petitioner Mark Robert Humphrey should not be dismissed for lack of jurisdiction.