Opinion
27333-21
06-01-2022
BRIAN PETER BERGER & GLENN C. FOSTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 4, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on December 8, 2021, by respondent's answer thereto. However, upon further review, it has come to the Court's attention that although the pleadings may reference the notice or notices of deficiency or determination upon which this litigation is based, no complete copy of such notice(s) has been provided. It is therefore advisable to ensure that the record herein is complete insofar as concerns the documentation relevant to establish the Court's jurisdiction over all parties and taxable periods. Accordingly, upon due consideration, it is
ORDERED that, on or before June 30, 2022, respondent shall file either: (1) An appropriate jurisdictional motion as to either or both petitioners; and/or (2) a report establishing the basis or bases for the Court's jurisdiction either or both and attaching thereto a copy of any supporting documentation.