Opinion
9159-23S
05-22-2024
CHRISTOPHER J. NOVAK & JENNIFER M. NOVAK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Emin Toro Judge
This case is currently calendared for trial during the Court's September 30, 2024, Portland, Oregon, trial session. On May 15, 2024, petitioners filed a Motion to Dismiss on Ground of Mootness (Doc. 11).
Petitioners seek review of a purported Notice of Deficiency. No Notice of Deficiency is attached to the Petition. On July 28, 2023, respondent filed an Answer. Respondent's Answer denies that a Notice of Deficiency was issued to petitioners and asserts that the only Notice properly in dispute in this case is the Notice of Determination Concerning Collection Action dated May 9, 2023, issued with respect to petitioners' taxable years 2015, 2017, and 2018. A copy of that May 9, 2023, Notice of Determination is attached to respondent's Answer. Petitioners have not contested respondent's position, and a review of the record shows no Notice of Deficiency to be at issue.
Upon due consideration and further review of the record in this case, it is hereby
ORDERED that, on or before June 12, 2024, petitioners shall show cause in writing why the caption should not be changed by adding "L" to the docket number to reflect that the Petition was filed in response to a Notice of Determination Concerning Collection Action.