Opinion
1628-24S
09-11-2024
ALEJANDRO FUENTES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Jennifer E. Siegel Special Trial Judge
Upon due consideration of the notice upon which this case is based, and for cause, it is
ORDERED that the Proposed Stipulated Decision submitted by the parties on September 9, 2024, is hereby recharacterized as the parties' Stipulation of Settled Issues. It is further
ORDERED that the parties shall, on or before September 30, 2024, show cause in writing why this case should not be dismissed for lack of jurisdiction on the ground the petition was not timely filed.