Opinion
10604-20S
09-01-2021
Siva Nathan & Anuradha Nathan, Petitioners v. Commissioner of Internal Revenue, Respondent
ORDER TO SHOW CAUSE
Diana L. Leyden Special Trial Judge.
This case is calendared for trial at the September 27, 2021, Atlanta, Georgia, Trial Session of the Court.
On July 15, 2020, the petition in this case was filed and signed by petitioners, Siva Nathan and Anuradha Nathan. Petitioners attached to the petition a notice of deficiency issued to petitioner Anuradha Nathan for tax year 2016. In the notice of deficiency respondent proposes a deficiency and additions to tax under sections 6651(a)(1) and (2) of the Internal Revenue Code with respect to a substitute for return for 2016 for petitioner Anuradha Nathan. The petition does not include a notice of deficiency issued to petitioner Siva Nathan for 2016. For cause, it is
ORDERED that, on or before September 14, 2021, the parties shall show cause in writing why this case should not be dismissed for lack of jurisdiction as to petitioner Siva Nathan on the ground that no valid notice of deficiency has been issued to petitioner Siva Nathan with respect to 2016 which would confer jurisdiction on this Court.
1