Opinion
15155-21S
11-01-2021
Jimmy A. Wiggins & Priscilla M. Wiggins Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
MAURICE B. FOLEY CHIEF JUDGE
On September 17, 2021, the parties filed a proposed stipulated decision for the Court's consideration. Upon review of the record, however, it appears that petitioners may have paid the tax liability for their 2018 tax year prior to the issuance of the notice of deficiency. If so, the notice of deficiency issued to petitioners for their 2018 tax year is invalid and this Court lacks jurisdiction of this case.
Upon due consideration, it is
ORDERED that, on or before November 22, 2021, the parties shall show cause in writing why this case should not be dismissed for lack of jurisdiction on the ground that the notice of deficiency on which this case is based is invalid. We will hold the parties' proposed stipulated decision pending resolution of the jurisdictional issue in this case.