Opinion
14836-22L
06-05-2023
MICHAEL A. PAWLAK & GAY L. PAWLAK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan Chief Judge.
On May 16, 2023, the parties filed in the above-docketed matter a joint Motion To Consolidate, seeking to consolidate this case at Docket No. 14836-22L with that at Docket No. 12713-22L. However, review of such motion and the records of these cases has raised questions regarding the Court's jurisdiction over petitioner Gay L. Pawlak in this case as to the 2010 tax year, as the underlying notice of determination appears to have been issued solely to petitioner Michael A. Pawlak.
Accordingly, the premises considered, it is
ORDERED that, on or before June 30, 2023, the parties shall show cause in writing why this case at Docket No. 14836-22L should not be dismissed for lack of jurisdiction as to Gay L. Pawlak, on the ground that no notice of determination has been issued to her with respect to the 2010 taxable year. The Motion To Consolidate will be held in abeyance pending resolution of the jurisdictional question.