Opinion
17981-22
10-12-2022
JOHN MICHAEL KISTLER, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion To Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted, filed October 11, 2022, it is
ORDERED that, on or before November 2, 2022, petitioner shall file an Objection, if any, to respondent's above-referenced motion. Failure to file an objection may result in the granting of respondent's motion or other appropriate action of the Court. It is further
ORDERED that, on or before November 2, 2022, petitioner may file an amended petition. Petitioner is advised that any amended petition should contain clear and concise assignments of each and every error that petitioner alleges the Commissioner to have committed in the notice of determination concerning collection action issued to petitioner for the 2008 through 2012 tax years. Further, that amended petition should contain clear and concise lettered statements of the facts on which petitioners base the assignments of error. See Rule 331(b) (4), (b)(5), Tax Court Rules of Practice and Procedure.