Opinion
21815-22S
02-08-2023
JAMES PARKER & ORA COFFER PARKER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan Chief Judge
On February 6, 2023, respondent filed a Motion to Change or Correct Caption, requesting that the caption of this case be amended to read: "James Parks and Ora Coffer-Parks, Petitioners v. Commissioner of Internal Revenue, Respondent". However, upon further review of the record, it appears that the notice of deficiency on which this case is based and which was attached to the petition was issued to Park Resources Inc.
Upon due consideration of the foregoing, it is
ORDERED that, on or before March 3, 2023, the parties shall show cause in writing why an Order should not be issued changing the caption of this case to read: "Park Resources Inc., Petitioner v. Commissioner of Internal Revenue, Respondent".