Opinion
25119-21
06-21-2022
KEVIN A. PAGE & JULIE L. PAGE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 12, 2021, petitioners filed the petition to commence this case. On June 15, 2022, the parties filed a proposed stipulated decision. Upon further review of the record, however, it appears the notice of deficiency on which this case is based was issued only to petitioner Kevin A. Page. No notice of deficiency issued to petitioner Julie L. Page has been produced by petitioners or respondent.
This Court is a court of limited jurisdiction. In a case seeking redetermination of a deficiency, the jurisdiction of the Court generally depends on the issuance of a valid notice of deficiency and the filing of a Tax Court petition within 90 days after the notice of deficiency is mailed (not counting Saturday, Sunday, or a legal holiday in the District of Columbia as the last day). See Internal Revenue Code section 6213(a). As the record does not contain a copy of a notice of deficiency issued to petitioner Julie L. Page, it appears that the Court may lack jurisdiction in this case with respect to Ms. Page.
Upon due consideration of the foregoing, it is
ORDERED that, on or before July 12, 2022, the parties shall show cause in writing why so much of this case relating to petitioner Julie L. Page should not be dismissed for lack of jurisdiction. We will hold in abeyance the parties' proposed stipulated decision.