Opinion
19295-19S
02-04-2022
Elias Ngowi, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge.
On January 5, 2022, the Court issued an Order to Show Cause in which the parties, on or before February 3, 2022, were to "show cause, in writing, why the Court, on its own motion, should not dismiss this case for lack of jurisdiction on the ground the petition was not timely filed."
On February 3, 2022, respondent filed a response and petitioner filed a response to response to the Court's Order to Show Cause each showed cause why the petition was timely and why the Court has jurisdiction. Upon due consideration, it is
ORDERED that the Court's Order to Show Cause dated February 3, 2022, is hereby discharged.