Opinion
19438-22S
06-12-2023
ROBERT RUSLER, 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 September 25, 2023, Los Angeles, California trial session. On September 1, 2022, the Court received an electronically filed a petition from petitioner. However, upon review of the Notice of Deficiency included in petitioner's petition, electronically filed on September 1, 2022, it was seen that the last date for petitioner to file a petition with the Court was August 29, 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 July 12, 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.