Opinion
5148-21S
04-05-2022
MAZDACK RASSI & SUZANNA ROBERTS-RASSI, Petitioners 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 June 13, 2022, New York City, New York remote trial session. On February 4, 2021, the Court received and filed a petition from petitioners. However, upon review of the Notice of Deficiency included in petitioner's petition, it was seen that the last date for petitioners to file a petition with the Court was January 20, 2021. The envelope that the petition was sent in bears a postmark of the date sent as January 26, 2021, therefore it appears that the petition was not timely filed with the Court and the Court lacks jurisdiction to hear the case. Upon due consideration, it is hereby
ORDERED that, on or before May 4, 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. 1