Opinion
3956-23
05-19-2023
ELLIS BARTON GRAHAM & TIFFINEY GRAHAM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 15, 2023, respondent filed a Motion for More Definite Statement Pursuant to Rule 51 of the Tax Court Rules of Practice and Procedure.
Upon due consideration, and for the reasons set forth in respondent's Motion, it is
ORDERED that respondent's above-referenced Motion is granted. It is further
ORDERED that, on or before June 9, 2023, petitioners shall file with the Court a proper amended petition (see form attached), which shall include (1) the date(s) of the notice(s) of deficiency or notice(s) of determination in dispute and the taxable year(s) for which such notice(s) was/were issued; (2) clear and concise lettered assignments of each and every error which petitioners allege to have been committed by respondent (i.e., the Internal Revenue Service) in the notice(s) of deficiency or notice(s) of determination underlying this proceeding; and (3) clear and concise lettered statements of the facts on which petitioners base the assignments of error. See Rules 34(b) and 331(b)(4) and (5), Tax Court Rules of Practice and Procedure. It is further
ORDERED that petitioners shall attach to the amended petition filed pursuant to this Order a copy of each notice on which petitioners rely to establish the jurisdiction of the Court over this proceeding.
Petitioners are informed that failure to comply in full with this Order may result in the dismissal of this case or other appropriate action by the Court.