Opinion
35349-21S
09-21-2022
ROSS JOSEPH PORTARO, III, 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 October 11, 2022, Winston-Salem, North Carolina trial session. On November 22, 2021, the Court received and filed a petition from petitioner. However, upon review of the Notice of Deficiency included in petitioner's petition, it was seen that the last date for petitioner to file a petition with the Court was November 15, 2021. The envelope that the petition was sent in does not appear to bear a 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 October 5, 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.