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.