Opinion
12742-23
01-22-2024
RAUL J. VELARDE & XIMENA P. CLARO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Patrick J. Urda Judge
This case is currently calendared for trial at the Court's Baltimore, Maryland trial session, scheduled to begin April 8, 2024.
On January 18, 2024, the parties filed a proposed stipulated decision and settlement stipulation. The petition in this case was electronically filed on August 11, 2023. The Commissioner subsequently filed his answer therein attaching a copy of the notice of deficiency issued to petitioners Raul J. Velarde and Ximena P. Claro dated May 22, 2023, for taxable year 2020. The Court notes, however, that the notice of deficiency attached to the answer identifies the deadline for filing a petition in this case as August 9, 2023. Upon due consideration, it is
ORDERED that, on or before February 20, 2024, the parties shall file a response to this Order, showing cause, in writing, as to why the Court, on its own motion, should not dismiss this case for lack of jurisdiction on the ground that the petition in this case was untimely pursuant to I.R.C. section 6213(a) or 7502.