Opinion
13164-22S
02-23-2023
MARIETTA NELSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Eunkyong Choi Special Trial Judge
This case is calendared for trial at the Court's April 11, 2023, New York City, New York trial session. On May 31, 2022, the Court received and filed a petition from petitioner. However, upon review of the Notice of Deficiency included in petitioner's petition, it was seen that the last date for petitioner to file a petition with the Court was May 23, 2022. The envelope that the petition was sent in bears a postmark of the date sent being May 24, 2022. Therefore, it appears that the petition was not timely filed with the Court.
Upon due consideration, it is hereby
ORDERED that, on or before March 27, 2023, the parties shall show cause in writing as to why the Court, on its own motion, should not dismiss this case for Lack of Jurisdiction upon the ground that the petition in this case was not filed within the time prescribed by I.R.C. § 6330 or § 7502.
Petitioner is advised that the failure to respond to this Order to Show Cause may result in the dismissal of this case.
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