Opinion
2720-21S
08-16-2021
James Thomas Murphy & Patricia A. Murphy Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley Chief Judge.
On August 5, 2021, the parties filed a Proposed Stipulation Decision. However, upon review of the record, it appears that petitioners paid the tax liability for the 2018 taxable year before the issuance of the notice of deficiency, and that, consequently, the notice of deficiency is invalid.
The foregoing considered, it is
ORDERED that, on or before September 7, 2021, the parties shall file a response in writing, showing cause why this case should not be dismissed for lack of jurisdiction on the ground that the notice of deficiency is invalid.