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Wideman v. Comm'r of Internal Revenue

United States Tax Court
Mar 21, 2023
No. 15258-22 (U.S.T.C. Mar. 21, 2023)

Opinion

15258-22

03-21-2023

KIMBERLI S. WIDEMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER TO SHOW CAUSE

Travis A. Greaves, Judge

On March 3, 2023, the parties filed a Proposed Stipulated Decision for the Court's consideration in this case. However, upon further review of the record, it appears that the Petition may not have been timely filed. The Petition seeks review of a Notice of Deficiency dated April 8, 2022, and addressed to petitioner at a mailing address within the United States. This suggests that the 90-day period for filing a timely petition with the Tax Court as to that Notice may have expired on July 7, 2022, as stated therein. The Petition in this case was received by the Court electronically and filed on July 10, 2022. If, as it appears, the Petition was not timely filed, we would lack jurisdiction over this matter. See I.R.C. §§ 6213(a), 7502; Hallmark Research Collective v. Commissioner, No. 21284-21, 159 T.C. (Nov. 29, 2022). Accordingly, we will direct the parties as set forth below.

Upon due consideration and for cause, it is

ORDERED that, on or before April 21, 2023, each party shall file a response showing cause in writing why the Court, on its own motion, should not dismiss this case for lack of jurisdiction on the ground that the Petition was not timely filed.


Summaries of

Wideman v. Comm'r of Internal Revenue

United States Tax Court
Mar 21, 2023
No. 15258-22 (U.S.T.C. Mar. 21, 2023)
Case details for

Wideman v. Comm'r of Internal Revenue

Case Details

Full title:KIMBERLI S. WIDEMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Mar 21, 2023

Citations

No. 15258-22 (U.S.T.C. Mar. 21, 2023)