Opinion
13510-21
05-12-2022
MARK F. JANOWIAK & LAUREN JANOWIAK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
This case is currently calendared on the Court's Atlanta, Georgia, trial session, scheduled to begin September 12, 2022.
On April 22, 2021, a petition was filed commencing the above-docketed matter, and on August 24, 2021, the Commissioner filed an answer thereto. In the petition, the petitioners Mark F. Janowiak and Lauren Janowiak attached a copy of the underlying notice of deficiency for 2016 issued solely to petitioner Mark F. Janowiak. The Court needs clarification on the jurisdictional status of this proceeding as to petitioner Lauren Janowiak.
Accordingly, it is
ORDERED that, on or before June 1, 2022, the Commissioner shall file either a report establishing the basis or bases of the Court's jurisdiction as to Lauren Janowiak (attaching a copy of any supporting documentation) or an appropriate jurisdictional motion as to petitioner Lauren Janowiak.