Opinion
12596-22
04-05-2023
RHONDA LYNN DENTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Alina I. Marshall Judge
On March 23, 2023, the parties submitted a Proposed Stipulated Decision. A review of the record and the notice of deficiency upon which this case is based indicates that the last day to timely file a petition with the Tax Court was April 4, 2022. The petition was submitted electronically on June 6, 2022. Accordingly, the petition may not have been timely filed and, if so, this Court is without jurisdiction in this case. Upon due consideration, it is
ORDERED that, on or before April 25, 2023, the parties shall show cause in writing why this case should not be dismissed for lack of jurisdiction on the ground that the petition was not filed within the time prescribed by the Internal Revenue Code.