Opinion
30671-21
10-24-2022
MARK K. TANAKA & DEBORAH A. TANAKA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE
On September 1, 2022, respondent filed a Motion To Dismiss for Lack of Jurisdiction on the ground the petition was not filed timely as to the deficiency notice issued to petitioners for tax year 2018.
On October 20, 2022, the parties filed a Proposed Stipulated Decision.
In view of the foregoing, it is
ORDERED that, on or before November 14, 2022, respondent shall file a Report concerning the the present status of this case, including respondent's position as to whether the Court has jurisdiction to redetermine a deficiency and penalty in this case for 2018.