Opinion
185-23
04-04-2024
JOSE MANUEL RAMOS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Elizabeth A. Copeland, Judge
This Order requires Petitioner, Jose Manuel Ramos, to respond in writing by May 1, 2024.
This case is calendared for trial at the Trial Session of the Court scheduled to commence on May 13, 2024, at the U.S. District Courthouse - Southern District of Iowa located at 123 East Walnut Street in Des Moines, Iowa 50309.
On March 25, 2024, Respondent filed with the Court a Motion to Dismiss for Lack of Jurisdiction. Respondent is asking that this case be dismissed on the ground that the Petition was not timely filed under I.R.C. §§ 6213(a) or 7502. Respondent informed the Court that the 90-day filing period expired on December 8, 2022, but the Petition was not filed until January 5, 2023.
Petitioner is encouraged to contact the low-income taxpayer clinic (LITC) in his locale for assistance in responding to this motion, namely: Iowa Legal Aid LITC at (800) 532-1275.
Upon due consideration, and for cause, it is
ORDERED that, on or before May 1, 2024, Petitioner shall show cause in writing why this case should not be dismissed for lack of jurisdiction, on the ground that the Petition was not mailed to or filed with the Tax Court within the time prescribed by I.R.C. §§ 6213(a) or 7502.