Opinion
8168-22S
03-17-2023
ADRIANA E. RODRIGUEZ, 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 May 30, 2023, Winston-Salem, North Carolina trial session. On April 4, 2022, the Court received and filed a petition from petitioner. However, upon review of the Notice of Deficiency included in petitioner's petition, filed on April 4, 2022, it was seen that the last date for petitioner to file a petition with the Court was March 28, 2022. The envelope that the petition was sent in does not appear to bear a postmark of the date sent, the tracking information indicates that it came into possession of the post office on March 30, 2022, therefore it appears that the petition was not timely filed with the Court.
Upon due consideration, it is hereby
ORDERED that, on or before April 14, 2023, 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.
Petitioner is advised that the failure to respond to this Order to Show Cause may result in the dismissal of this case.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you currently file in paper and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov. If you are not currently registered for eAccess, please do not attempt to electronically file documents in a pending case without first contacting dawson.support@ustaxcourt.gov.