Opinion
18120-21
04-18-2022
LOUIS OLIVER HOGAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge
On May 21, 2021, a petition was filed commencing the above-docketed matter, which petition was followed on September 27, 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 May 6, 2022, respondent shall file either: (1) An appropriate jurisdictional motion; and/or (2) a report establishing the basis or bases for the Court's jurisdiction and attaching thereto a copy of any supporting documentation.