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Dale-Winters v. Comm'r of Internal Revenue

United States Tax Court
May 2, 2022
No. 36018-21 (U.S.T.C. May. 2, 2022)

Opinion

36018-21

05-02-2022

ADONIJAH DALE-WINTERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

MAURICE B. FOLEY CHIEF JUDGE

On March 1, 2022, respondent filed in the above-docketed matter a Motion To Dismiss for Failure To State a Claim Upon Which Relief Can Be Granted. However, upon review, it appears that respondent failed to take into account the totality of the petition, in particular a statement attached thereto wherein petitioner explains her disagreement with a principal disallowance in the underlying notice of deficiency for 2020. Such qualifies for the minimal notice pleading required to establish a claim.

Accordingly, the premises considered, it is

ORDERED that respondent's just-referenced March 1, 2022, motion is denied.


Summaries of

Dale-Winters v. Comm'r of Internal Revenue

United States Tax Court
May 2, 2022
No. 36018-21 (U.S.T.C. May. 2, 2022)
Case details for

Dale-Winters v. Comm'r of Internal Revenue

Case Details

Full title:ADONIJAH DALE-WINTERS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: May 2, 2022

Citations

No. 36018-21 (U.S.T.C. May. 2, 2022)