Opinion
8765-22S
11-29-2022
DORA PACHECO, 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 March 6, 2023, Las Vegas, Nevada trial session. On April 11, 2022, the Court received and filed a petition from petitioner. However, upon review of the Notice of Deficiency included in petitioner's petition, filed on April 11, 2022, it was seen that the last date for petitioners to file a petition with the Court was April 4, 2022. The envelope that the petition was sent in does not appear to bear a legible postmark of the date sent, therefore it appears that the petition was not timely filed with the Court.
Upon due consideration, it is hereby
ORDERED that, on or before December 28, 2022, 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.